COLUMBUS, Ohio – A federal judge on Tuesday temporarily halted Ohio from enforcing a new rule requiring people to provide proof of U.S. citizenship when registering to vote at a motor vehicle bureau, a requirement that took effect for the first time this year.
Republican Secretary of State Frank LaRose said his office would appeal the decision immediately.
U.S. District Court Judge Solomon Oliver Jr. in Cleveland issued the ruling in a lawsuit filed by the Democrat-aligned Elias Law Group on behalf of the Ohio Alliance of Retired Americans and the progressive organization Red Wine & Blue. Oliver found that the state requirement appears to clash with the National Voter Registration Act, which he said carries controlling authority.
The injunction pauses enforcement of the documentation requirement before the Oct. 5 voter registration deadline for this fall’s midterm elections.
The decision lands as President Donald Trump urges Congress to approve legislation that would make documentary proof of citizenship a requirement for voter registration, along with other election changes.
Ohio is one of several states implementing proof-of-citizenship laws for the first time this year. South Dakota, Utah and Wyoming have enacted similar requirements for this year’s midterms, while Arizona already had such a rule in place for state and local elections.
Also on Tuesday, the League of Women Voters and a Sioux Falls voter sued over South Dakota’s new proof-of-citizenship rule for voter registration. The plaintiffs are asking, among other things, for a judge to require the state to accept photocopies of eligible identification documents and to withdraw guidance that says people using certain forms of ID must register in person.
Ohio added the requirement last year to its motor voter law. In his ruling, Oliver wrote that the provision goes beyond “the signed attestation to U.S. citizenship” accepted through Ohio’s other voter registration methods. As a result, he said, the challenged provision likely conflicts with the NVRA because it demands more than “the minimum amount of information necessary.”
He further found that Ohio’s overall “motor voter” registration process has illegally been limiting the option to sign up to vote to those who successfully obtain a driver’s license, rather than offering it to everyone who submits an application for one, as federal law requires.
Ben Stafford, a partner at Elias Law, said in a statement that Ohio voters would now be able to register at the BMV without the requirement to show citizenship paperwork. He described the regulation as “exactly the type of government-imposed barrier that the NVRA exists to prevent.”
The judge’s order prevents Ohio from requiring any driver’s license applicant to produce proof-of-citizenship documents before being offered the chance to register to vote, even those applicants turned away for lack of the proper paperwork. It doesn’t cover applicants who indicate they are not U.S. citizens.
LaRose criticized the ruling and pointed to a case in Franklin County, which includes Columbus, that he said proves the process Solomon has required doesn’t work. The case involved a lawful permanent resident of the U.S. who was ineligible to vote but did so in 2018 after she said a clerk at the Ohio Bureau of Motor Vehicles mistakenly led her to believe she was allowed to do so. The woman was found not guilty by reason of entrapment.
“Under this order, the Bureau of Motor Vehicles would be required to offer a voter registration form to a person who is applying for a driver’s license, even if that person can’t verify that they’re a citizen,” LaRose said in a statement. “We strongly disagree with that decision, and I’ve asked our legal team to file an immediate appeal.”
Solomon’s decision aligned with court decisions elsewhere.
In May, in the first major legal test of Trump’s citizenship-related election demands, a federal judge in New Hampshire ruled that the state must make voter registration easier by letting applicants attest to their U.S. citizenship if they don’t have the documents to prove it.
When New Hampshire’s law took effect for the first time, for local elections in 2025, some election clerks said they knew of would-be voters who couldn’t produce the necessary documents and were turned away — for example, women who had changed their last names when they married.
In June, a federal judge permanently barred the Trump administration from implementing most of the president’s first executive order on elections, including a requirement that people show documentary proof of citizenship when they register to vote. The ruling by U.S. District Court Judge Denise Casper in Boston effectively converted what was a preliminary injunction blocking much of the attempted overhaul into a permanent one.
A 2025 University of Maryland study estimates that 21.3 million Americans eligible to vote do not have documents or have easy access to the documents required to prove citizenship.
