0.01%. That's roughly how much of state voter rolls turned out to be real noncitizen registrants when states actually checked.
Louisiana found 79 who voted since the 1980s, Ohio 138, Texas 33 referred from 2024. Real, but tiny. And the headline numbers collapsed: Texas's '6,500 removed' was 581 confirmed. About two-thirds of Alabama's 3,251 'noncitizens' were citizens. The real weak spot? Government data plumbing, like Oregon's DMV errors and Arizona's 200,000+ miscoded records.
PRO: Routine SAVE/DMV checks catch real cases and agency errors.
CON / COST: Initial flags are mostly wrong; Kansas proof rules blocked 31,089 citizens.
SOCIETY: Local noncitizen voting weakens citizenship and trust; blanket purges hit citizens.
Full analysis
Non-Citizen Voting in the U.S.: Policy Assessment
What the laws are, why they exist, what local audits and state referrals actually found, and a verdict. Revised Nov 4, 2026 to a local-evidence standard.
Content as of Nov 4, 2026, 8:34 PM ET. Source Page: PolicyBombs canvas
Long-form deep analysis. Companion to the 10-minute quick reference (01-non-citizen-voting-summary.docx).
Contents
- 10-Minute Voter Guide
- What changed in this revision
- Key facts
- 1. What is the policy
- 2. Why it exists
- 3. Realized effects
- 4. Good or bad for society
- Anomaly and case table
- Who supports / who opposes
- References
10-Minute Voter Guide
Who’s for / against: For local noncitizen voting: DC Council (D), SF and Oakland voters, NYC Council (D). For citizenship-proof rules: House Republicans (SAVE Act) plus 4 House Democrats, the 2024 GOP platform, and Trump’s March 2025 executive order. Most Democrats oppose the SAVE Act as voter suppression.
Some cities (San Francisco, DC, about 11 Maryland towns) let noncitizens vote in local races. Voting in state or federal races is a crime for noncitizens. Since 2024, states have run their rolls through DMV and federal immigration (SAVE) data and found real noncitizens registered, and some who voted: Louisiana 79 who voted at least once since the 1980s, Ohio 138, Georgia 9, Oregon up to 9 (registered by a DMV error), Texas 33 referred from 2024 using SAVE. That is about 0.01% of rolls, far fewer than the big numbers politicians announced. Texas’s ‘6,500 removed’ was really 581 confirmed. About two-thirds of Alabama’s 3,251 ‘noncitizens’ were citizens. Virginia’s purges swept in citizens who checked the wrong DMV box. The real weak spot is government data plumbing (Oregon’s DMV, Arizona’s 200,000-plus records coded with citizenship proof they never gave), not mass fraud.
Pros of stricter citizenship checks | Cons |
+ Every state that checked found some real noncitizen registrants; a few hundred votes can decide local races + The revamped SAVE database (2025) can confirm status in bulk for free + Exposes agency errors (Oregon, Arizona) that attestation never caught | – Initial flags are mostly wrong: AL two-thirds citizens; TX 6,500 shrank to 581; Idaho 678 to 36 – Pre-election purges were blocked or settled under NVRA’s 90-day rule (VA, AL) – Documentary-proof mandates block far more citizens than they catch noncitizens (Kansas: 31,089) |
Bottom line: Noncitizen voting is real, documented in every state that looked, and almost always tiny (about 0.01% of rolls), often traced to agency mistakes or confused immigrants rather than organized fraud. Support routine SAVE and DMV checks done individually with notice. Distrust headline purge numbers until follow-up confirms them. Local noncitizen voting remains a weak policy. |
What changed in this revision
- Added 2024–2026 state and county findings: Virginia, Texas, Alabama, Oregon, Arizona, Louisiana, Utah and Idaho, each with its follow-up result.
- New evidence moves the verdict slightly: the problem is no longer ‘close to zero’ but ‘small and real’, with confirmed votes in several states. Government data errors are now a documented cause. Routine verification is a stronger recommendation than before; the verdict against blanket documentary-proof mandates stands.
- Added a corruption and incentive lens: officials on both sides inflated (TX, AL) or ignored (OR, AZ) the problem.
Key facts
Policy | Year | Status (Nov 2026) | Key number |
|---|---|---|---|
SF Prop N: noncitizen parents vote for school board | 2016 | In force; upheld on appeal Aug 2023 | 235 noncitizens voted in the 2022 recall; about 44,000 eligible (city estimate) |
NYC Local Law 11: about 800,000 green-card holders and work-authorized residents vote in city races | 2022 | Void; NY Court of Appeals 6–1, Mar 20, 2025 | Never used in an election |
Takoma Park, MD: all residents vote in city elections | 1992 | In force (about 11 MD towns) | 347 registered, 72 voted (2017) |
DC Local Resident Voting Rights Act | 2022 | In force; House repeal bill passed, stalled in Senate | House repeal vote 266–148 (June 10, 2025) |
18 U.S.C. 611 (added by IIRIRA) | 1996 | Federal law | Up to 1 year in prison for voting in a federal race |
State constitutional bans on noncitizen voting | 2018–2024 | 8 of 8 passed in 2024 | Ohio 2022 and Louisiana 2022 passed by wide margins |
SAVE / SAVE America Act: proof of citizenship to register | 2024–2026 | Passed House; failed in Senate 48–50 (June 4, 2026) | House 218–213 (Feb 2026) |
Georgia citizenship audits | 2022, 2024 | Done | 2022: 1,634 attempted, 0 registered. 2024: 20 on 8.2M rolls, 9 voted |
Ohio referrals | 2024 | Referred to the state attorney general | 597 referred (138 voted, 459 registered only) |
1. What is the policy
Item | Detail |
|---|---|
Federal ban | 18 U.S.C. 611, added by IIRIRA in 1996, makes it a crime for a noncitizen to vote in a federal election (fine, up to 1 year). There is an exception for local elections that allow noncitizens to vote, plus a reasonable-belief defense added in 2000. 18 U.S.C. 1015(f) and 8 U.S.C. 1182/1227 add false-claim penalties and grounds for deportation. |
San Francisco Prop N (2016) | Charter amendment. Noncitizen parents, guardians and caregivers of SF children can vote for the Board of Education, regardless of immigration status. They must register separately for each election. The Board of Supervisors made it permanent in 2021. Superior Court struck it down in July 2022 (Lacy v. SF). The 1st District Court of Appeal reversed in August 2023, citing charter-city home rule. |
NYC Local Law 11 (2022) | Lawful permanent residents and work-authorized noncitizens with 30 days of residency could vote for mayor, comptroller, public advocate, borough president and council. It took effect Jan 9, 2022 without a mayoral signature. Struck down by Supreme Court, Richmond County (2022), Appellate Division (2024) and the Court of Appeals (Fossella v. Adams, Mar 20, 2025, 6–1). Article II §1 of the state constitution limits voting to citizens. |
Maryland municipalities | State law lets towns set their own electorate. Takoma Park has allowed it since 1992 (first election 1993). About 11 towns do now, including Hyattsville, Mount Rainier and Riverdale Park. Also allowed in a few Vermont towns, such as Winooski and Montpelier. |
District of Columbia (2022) | The Local Resident Voting Rights Amendment Act lets noncitizens who have lived in DC 30 days, including undocumented people and diplomats, vote in local elections. It took effect Feb 23, 2023, after Congress’s review period ran out (the House voted to disapprove; the Senate didn’t act). H.R. 884 (repeal) passed the House 266–148 with 56 Democrats on June 10, 2025. It has been in a Senate committee since. |
State constitutional amendments | Amendments changing "every citizen" to "only citizens": North Dakota (2018); Alabama, Colorado and Florida (2020); Ohio (Issue 2) and Louisiana (2022). In 2024: Idaho, Iowa, Kentucky, Missouri, North Carolina, Oklahoma, South Carolina and Wisconsin. All passed. |
SAVE Act / SAVE America Act | Would amend the NVRA to require documents proving citizenship (passport, birth certificate plus ID, etc.) to register for federal elections. The 2026 version adds photo ID and sends voter rolls to DHS. It passed the House in 2024, 2025 and Feb 2026 (218–213). It failed as a Senate amendment 48–50 on June 4, 2026. Courts have blocked executive-order versions. |
2. Why it exists
Stated case for local noncitizen voting | Stated case for bans and proof of citizenship |
+ No taxation without representation: residents pay local taxes and use local schools + Parents should have a say over their children’s schools (SF) + Integration and civic habit before naturalization + There is historical precedent: about 40 states or territories let noncitizens vote at some point before 1926 | – Citizenship is what defines the political community – Separate rolls cause confusion and can lead to accidental illegal federal voting – Lowers the incentive to naturalize – Attestation alone, without verification, invites fraud and undermines trust |
Underlying drivers on the left: progressive city councils and immigrant-rights groups (NYC: Our City, Our Vote; SF: Chinese Progressive Association) want to grow constituencies that lean their way and to signal values. Few noncitizens actually use the right, which suggests symbolism matters as much as representation.
Underlying drivers on the right: the ballot amendments and the SAVE Act ban things that are mostly already illegal (only local law allowed noncitizen voting anywhere). They are partly turnout tools: they put the immigration issue on the ballot and set up a narrative of stolen elections. Proof-of-citizenship requirements also burden eligible citizens who lack documents. Those citizens skew poorer and younger, and the parties disagree about who they vote for.
Some Democrats cross over (56 House Democrats on the DC repeal, and wide margins in blue-leaning electorates on amendments). Noncitizen voting is unpopular with the public, so the right gains more politically by forcing votes on it.
3. Realized effects
Legal local voting: low uptake
Item | Detail |
|---|---|
San Francisco | 235 noncitizens voted in the high-profile 2022 school board recall, out of about 44,000 estimated eligible (SF Examiner, citing city figures). The Department of Elections has not published a separate noncitizen count for Nov 2024; noncitizen ballots were merged into the certified totals. Fear of immigration enforcement is the reason most often given. |
Takoma Park | 347 noncitizens registered and 72 voted in 2017 (about 20%). The city stopped reporting the figure separately after that. |
Hyattsville | About 230 city-only registrants and roughly 40 voters (Washington Times, 2024). |
NYC | Zero; the law was enjoined before any election. |
Illegal voting in state and federal elections: rare
Study / audit | Finding | Source lean |
|---|---|---|
Georgia audit 2022 | 1,634 noncitizens tried to register over 25 years; none got on the rolls | GOP Secretary of State |
Georgia audit 2024 | 20 noncitizens among 8.2M registrants; 9 had voted | GOP Secretary of State |
Ohio referrals 2024 | 597 apparent noncitizens referred: 138 voted, 459 only registered (about 8M registered voters) | GOP Secretary of State |
Michigan 2024 | 15 potential noncitizen votes among more than 5.7M ballots | Dem Secretary of State |
Brennan Center 2017 | About 30 suspected noncitizen votes referred among 23.5M in 42 jurisdictions (2016), or 0.0001%. 40 of 42 jurisdictions reported zero. Officials self-reported, and NYC declined to participate | Progressive |
Heritage fraud database | 1,619 total fraud cases. 89 are noncitizen voting cases since 2000 (16 involving undocumented immigrants), per an American Immigration Council count. Brennan’s 2017 review of the then-database counted 41 | Conservative |
Richman, Chattha & Earnest 2014 (Electoral Studies, CCES data) | Estimated 6.4% of noncitizens voted in 2008 and 2.2% in 2010 | Academic; disputed |
Ansolabehere et al. 2015 | Ansolabehere, Luks & Schaffner 2015: even a 0.1% citizenship-misclassification rate produces the apparent voters. Among panel respondents who consistently said they were noncitizens, none was a validated voter, so the best estimate is about zero. Richman’s own 2023 Arizona expert report found 1,934 records of possible noncitizens on 4M rolls (0.04%), per Brennan | Academic rebuttal |
Caveat: audits only find people who show up in DHS/SAVE or DMV data, so the true count could be somewhat higher. Even so, every audit lands on rates of about 0.01% or lower. That is far below the margin in nearly every race, and some of the cases are confused green-card holders, not deliberate fraud.
Local and state findings, 2024–2026 (verified this revision)
State / county | Headline claim | What follow-up found | Status |
|---|---|---|---|
Virginia (EO 35, Aug 2024) | About 1,600 removed Aug–Oct 2024; 6,303 ‘noncitizens’ removed July 2022–July 2024 | Washington Post and state officials: many were citizens who checked the wrong DMV box. Radio IQ reviewed 650+ election-crime cases over 20 years and found no noncitizen voting convictions. Fairfax referred about 800 people; its prosecutor said failing to answer a letter isn’t a crime. SCOTUS allowed the purge (Oct 30, 2024); an Apr 2026 settlement bars it within 90 days of federal elections | Mostly unsubstantiated as illegal voting |
Texas (Aug 2024) | 6,500 noncitizens removed; 1,930 with voting history sent to AG | SOS report: 581 confirmed noncitizens over 3 years; the rest didn’t answer notices. Reporters found citizens on the list. The 1,930 narrowed to about 100-plus investigations. June 2025: SOS referred 33 SAVE-flagged noncitizens who voted in Nov 2024 | Inflated; 33 referrals pending |
Alabama (Aug 2024) | 3,251 noncitizen ID holders made inactive | At least 2,074 were eligible citizens (state’s own sworn filing); 106 asked to be removed. Judge Manasco (Trump appointee) enjoined it. DOJ dropped its suit in 2025 | Mostly false positives |
Oregon (Sept–Oct 2024) | DMV registered 1,259 people without proof of citizenship (plus 123 more found Oct 2024; American Samoans coded as citizens since 2016) | 10 had voted; 1 confirmed citizen, so up to 9 potentially ineligible votes since 2021. Officials say no race was affected. After-action report blames systemic DMV error | Substantiated agency error |
Arizona (2024–2025) | About 218,000 voters coded as having shown citizenship proof due to an MVD flaw on pre-1996 licenses | Court let them vote full ballots in 2024. List fell to about 200,000 as documents were found. Most are believed to be longtime citizens | Agency error; citizenship mostly presumed |
Louisiana (Sept 2025, SAVE) | 390 noncitizens registered, 79 voted at least once since the 1980s | About 0.01% of 2.9M rolls. SOS: ‘not a systemic problem’; due process pending | Preliminary; referrals |
Utah (2025) | Full-roll citizenship check | 27 confirmed noncitizens removed; 25 probable; 5,007 unconfirmed (mostly old registrations). No confirmed illegal votes reported | Small |
Idaho (2024–2025) | 678 potential noncitizens flagged by DMV | SAVE confirmed 638 as citizens; 34 removed and referred; none voted in 2024. About 15 referred to the U.S. Attorney; 12 more flagged in 2025 | Small; pending |
Georgia, Ohio, Michigan (2022–2024) | See table above | GA 9 voted; OH 138 voted; MI 15 potential | Referred |
Pattern: every headline number shrank by 70–99% on follow-up, yet none shrank to zero. Confirmed noncitizen votes, summed across the states above, are in the low hundreds over many years against more than 30M registrants. That is below nearly every statewide margin, but within range of close local races (e.g. Paterson’s 9-vote rerun, Virginia HD-94’s 2017 tie).
Litigation scorecard
Item | Detail | Assessment |
|---|---|---|
California (charter city) | Lacy v. SF, 2023: allowed under home rule | Upheld |
New York | Fossella v. Adams, 2025: violates Art. II §1 and needed a referendum | Struck |
Maryland | State law lets towns set their own electorate; no appellate ruling has struck it down | In force |
Kansas proof of citizenship | Fish v. Kobach (D. Kan. 2018): 31,089 applicants blocked (14,770 suspended, 16,319 canceled). Affirmed as Fish v. Schwab (10th Cir. 2020), which found the evidence of noncitizen registration ‘scant’ | Struck |
Federal proof-of-citizenship EO | Blocked: courts say elections are for states and Congress | Blocked |
4. Good or bad for society
Verdict: Letting noncitizens vote locally is a net negative: its benefits are small, while it weakens the meaning of citizenship and damages trust in elections. Illegal noncitizen voting is small but real. 2024–2026 state checks confirmed votes in LA, OH, GA, OR and TX, and showed agency errors (Oregon, Arizona) are a real cause. Revised: routine SAVE and DMV verification is now clearly worth doing, done case by case and outside the 90-day window. Blanket documentary-proof mandates still block far more citizens than noncitizens, as the Alabama and Texas false positives show. Distrust headline purge numbers from either side. |
Strongest case FOR local noncitizen voting | Strongest case AGAINST |
+ Taxpaying residents and school parents get a voice over services they fund and use + Low risk: separate ballots, and 30 years in Takoma Park without scandal + Local democracy: SF voters chose it themselves, and the courts there upheld it | – Very low uptake (under 1% of eligible in SF) means the representation benefit is mostly symbolic – Separate rolls create real legal risk for immigrants (the N-400 voting question, deportation if they vote in the wrong race) – Weakens the incentive to naturalize, and the public doesn’t accept it, which feeds distrust and backlash |
Strongest case FOR SAVE-style proof | Strongest case AGAINST |
+ Attestation alone is a weak check, and audits keep finding a few cases + Public confidence: a large share of voters believe it is a problem + Simple rule: you verify before you register | – Millions of eligible citizens lack ready access to the documents (NPR, citing research) – Kansas’s 2013 proof-of-citizenship law blocked 31,089 registration applicants; it was struck down in Fish v. Kobach / Fish v. Schwab (10th Cir. 2020) – Already illegal; deterrence (prison plus deportation) is strong, and the cases are microscopic |
- Better approach: run routine checks of voter rolls against the SAVE database and DMV data to catch the cases audits find, with notice and a chance to respond so citizens aren’t wrongly removed.
- Keep 18 U.S.C. 611 as it is, and prosecute the deliberate cases.
- Cities wanting immigrant voice: fund naturalization drives, not separate electorates.
Anomaly and case table
Jurisdiction | Flagged | Confirmed / voted | Conclusion |
|---|---|---|---|
Texas 2024 | 6,500 / 1,930 | 581 confirmed; 33 referred (2025) | Inflated |
Alabama 2024 | 3,251 | 2,074+ citizens | Mostly false |
Virginia 2024 | About 1,600 (6,303 earlier) | 0 convictions in 20 years of records | Unsubstantiated |
Oregon 2024 | 1,259 + 123 | Up to 9 voted | Agency error |
Arizona 2024 | About 218,000 | Mostly presumed citizens | Agency error |
Louisiana 2025 | 390 | 79 voted (since 1980s) | Preliminary |
Ohio 2024 | 597 | 138 voted | Referred |
Georgia 2024 | 20 | 9 voted | Referred |
Idaho 2024 | 678 | 34 removed; 0 voted 2024 | Referred |
Utah 2025 | 10,718 unconfirmed | 27 confirmed noncitizens | Removed |
Who supports / who opposes
For = allow noncitizens to vote locally / oppose proof-of-citizenship mandates. Against = citizenship-only voting and proof requirements. Each row cites a numbered source below. Checked Nov 4, 2026.
Who | Party / level | Position | Evidence | Ref |
DC Council (Brianne Nadeau, D, lead sponsor) | Democrat / DC | For | Passed the Local Resident Voting Rights Amendment Act (B24-0300), letting noncitizen residents vote in DC local elections | [1] |
San Francisco & Oakland voters | CA local | For | SF Prop N (2016) and Oakland Measure S (2022) let noncitizen parents vote in school-board races | [2] |
Rep. Chip Roy (R-TX) and 216 House Republicans | Republican | Against | Sponsored the SAVE Act (H.R. 22), requiring documentary proof of citizenship to register; passed House 220–208 on Apr 10, 2025 | [3] |
Reps. Ed Case (HI), Henry Cuellar (TX), Jared Golden (ME), Marie Gluesenkamp Perez (WA) | Democrat (defectors) | Against | Voted yes on the SAVE Act, roll call 102 | [3] |
208 House Democrats; Senate Minority Leader Chuck Schumer (D-NY) | Democrat | For (qualified) | Voted no on SAVE Act; Schumer called it "noxious" and vowed to block it in the Senate (opposes the citizenship-proof bill, not a vote for noncitizen voting) | [4] |
President Donald Trump | Republican | Against | EO "Preserving and Protecting the Integrity of American Elections" (Mar 25, 2025) demands proof of citizenship on the federal form; parts blocked in court | [5] |
Republican Party | Platform | Against | 2024 platform calls to secure elections and ban noncitizen voting | [6] |
Voters in 8 states (ID, IA, KY, MO, NC, OK, SC, WI) | Ballot measures | Against | Approved 2024 constitutional amendments saying only citizens may vote | [7] |
Cross-party defectors: Four House Democrats crossed to back the SAVE Act in 2025. Many Democrats who oppose the SAVE Act also oppose noncitizen voting itself; their objection is about the paperwork burden on citizens.
How positions shifted: Noncitizen voting was common in many states into the 1920s; it became a partisan flashpoint after the 2016–2022 local measures. Republicans moved from opposing it to making proof-of-citizenship registration a top priority after 2024.
Not included or not fully verified: Could not source California statewide officials’ (e.g., Newsom’s) on-record position on local noncitizen voting; omitted.
Sources for this section:
- [1] DC Council: B24-0300 Local Resident Voting Rights Amendment Act (lims.dccouncil.gov) https://lims.dccouncil.gov/Legislation/B24-0300
- [2] Ballotpedia: Laws permitting noncitizens to vote (ballotpedia.org) https://ballotpedia.org/Laws_permitting_noncitizens_to_vote_in_the_United_States
- [3] House Clerk: Roll Call 102, H.R. 22 SAVE Act (Apr 10, 2025) (clerk.house.gov) https://clerk.house.gov/Votes/2025102
- [4] Newsweek: Democrats who voted for the SAVE Act; Schumer quote (newsweek.com) https://www.newsweek.com/full-list-democrats-who-voted-pass-save-act-2058404
- [5] White House: Preserving and Protecting the Integrity of American Elections (whitehouse.gov) https://www.whitehouse.gov/presidential-actions/2025/03/preserving-and-protecting-the-integrity-of-american-elections/
- [6] 2024 Republican Party Platform (presidency.ucsb.edu) https://www.presidency.ucsb.edu/documents/2024-republican-party-platform
- [7] Ballotpedia: Results for voting-related and noncitizen voting ballot measures, 2024 (ballotpedia.org) https://ballotpedia.org/Results_for_voting-related_and_noncitizen_voting_ballot_measures,_2024
References
[1] Fossella v. Adams decision (NY Court of Appeals, 2025). nycourts.gov. http://www.nycourts.gov/reporter/3dseries/2025/2025_01668.htm
[2] Lacy v. City and County of San Francisco (2023). justia.com. https://law.justia.com/cases/california/court-of-appeal/2023/a165899.html
[3] SF City Attorney: appeal court upholds program. sf.gov. https://www.sf.gov/news-appeal-court-upholds-san-franciscos-noncitizen-voting-program
[4] SF noncitizen turnout (235 in 2022 recall; 44,000 eligible). sfexaminer.com. https://www.sfexaminer.com/news/politics/sf-school-board-election-noncitizen-turnout-not-yet-clear/article_7d73cb42-a6c8-11ef-8f10-277b3a6993be.html
[5] SF Nov 2024 NCV outreach plan. sf.gov. https://www.sf.gov/sites/default/files/2024-07/November%202024%20NCV%20Outreach%20Plan.pdf
[6] Takoma Park: 30 years of non-citizen voting. takomaparkmd.gov. https://documents.takomaparkmd.gov/news/newsletter/2023/TPN_1023_FINAL.pdf
[7] PolitiFact on Takoma Park. politifact.com. https://politifact.com/article/2024/oct/21/a-maryland-city-has-let-noncitizens-vote-in-local/
[8] Washington Times: noncitizen turnout struggles. washingtontimes.com. https://www.washingtontimes.com/news/2024/jan/1/if-you-build-it-will-they-vote-cities-with-nonciti/
[9] H.R. 884 (DC repeal). congress.gov. https://www.congress.gov/bill/119th-congress/house-bill/884
[10] House roll call 163 (2025). clerk.house.gov. https://clerk.house.gov/Votes/2025163
[11] 18 U.S.C. 611. law.cornell.edu. https://www.law.cornell.edu/uscode/text/18/611
[12] NPR: SAVE Act fails in Senate (June 2026). npr.org. https://www.npr.org/2026/06/04/nx-s1-5751145/save-act-senate-vote-trump
[13] Reuters: what’s in the SAVE America Act. reuters.com. https://www.reuters.com/legal/government/what-is-trumps-bill-that-requires-proof-citizenship-vote-2026-03-17/
[14] Georgia SOS: 2022 audit referrals (1,634). sos.ga.gov. https://sos.ga.gov/news/secretary-raffensperger-refers-1600-noncitizen-registrants-local-das-gbi-state-election-board
[15] Ohio SOS: Aug 2024 referrals. ohiosos.gov. https://www.ohiosos.gov/office/media-center/categories/press-releases/2024-08-21
[16] AP: Ohio finds 597 noncitizens. apnews.com. https://apnews.com/article/ohio-voters-citizenship-referrals-42799a379bdda8bca7201d6c42f99c65
[17] Brennan Center: Noncitizen Voting, The Missing Millions. brennancenter.org. https://www.brennancenter.org/our-work/research-reports/noncitizen-voting-missing-millions
[18] Brennan Center: Noncitizen Voting is Vanishingly Rare. brennancenter.org. https://www.brennancenter.org/our-work/research-reports/noncitizen-voting-vanishingly-rare
[19] Brennan Center analysis of Heritage database (2017). brennancenter.org. https://www.brennancenter.org/sites/default/files/publications/HeritageAnalysis_Final.pdf
[20] American Immigration Council: Heritage’s own data (89 cases). americanimmigrationcouncil.org. https://www.americanimmigrationcouncil.org/blog/myths-about-noncitizen-voting-heritage-foundation-data/
[21] Richman, Chattha & Earnest (2014), Do Non-Citizens Vote in U.S. Elections?. odu.edu. https://digitalcommons.odu.edu/politicalscience_geography_pubs/11/
[22] Fish v. Schwab (10th Cir. 2020). justia.com. https://law.justia.com/cases/federal/appellate-courts/ca10/18-3133/18-3133-2020-04-29.html
[23] Ballotpedia: citizenship requirement ballot measures. ballotpedia.org. https://ballotpedia.org/History_of_citizenship_requirements_and_noncitizen_voting_ballot_measures
[24] SF certifies Nov 5, 2024 election. sf.gov. https://www.sf.gov/news–san-francisco-department-elections-certifies-november-5-2024-consolidated-general-election
[25] Heritage Election Fraud Database. heritage.org. https://electionfraud.heritage.org/
[26] Ansolabehere, Luks & Schaffner (2015), The perils of cherry picking low frequency events. stanford.edu. https://web.stanford.edu/group/bps/cgi-bin/wordpress/wp-content/uploads/2015/04/The-Perils-of-cherry-picking-low-frequency-events-in-surveys.pdf
[27] LegalClarity: SAVE Act status and state audit figures. legalclarity.org. https://legalclarity.org/will-the-save-act-pass-the-senate-votes-opposition-and-status/
[28] FFXnow: Fairfax referrals and VA purge. ffxnow.com. https://www.ffxnow.com/2024/10/15/fairfax-refers-possible-non-citizen-voters-for-prosecution-as-virginia-faces-lawsuits/
[29] Radio IQ: VA court records show no noncitizen convictions. wvtf.org. https://www.wvtf.org/news/2024-10-30/understanding-virginias-noncitizen-registered-voters
[30] Democracy Docket: VA purge case and 2026 settlement. democracydocket.com. https://www.democracydocket.com/cases/virginia-noncitizen-voter-purge-program-challenge/
[31] Texas Tribune/ProPublica/Votebeat: 6,500 inflated. texastribune.org. https://www.texastribune.org/2024/10/15/texas-noncitizen-voter-roll-removal-included-americans/
[32] Texas Tribune: 33 SAVE referrals (2025). texastribune.org. https://www.texastribune.org/2025/06/05/texas-secretary-state-noncitizen-voters-investigation/
[33] AP: judge halts Alabama purge. apnews.com. https://apnews.com/article/alabama-voter-purge-allen-secretary-state-judge-6cec74a5bc2afef14beae6827d4cf971
[34] DOJ dismisses Alabama suit (2025). justice.gov. https://www.justice.gov/opa/pr/us-department-justice-dismisses-biden-era-lawsuit-against-alabama-order-have-more-secure
[35] Oregon SOS: 9 potentially ineligible voters. oregon.gov. https://apps.oregon.gov/oregon-newsroom/OR/SOS/Posts/Post/dmv-potential-ineligible-voters-improper-registration-records
[36] Oregon DMV After-Action Report. oregon.gov. https://www.oregon.gov/odot/DMV/docs/After-Action-Report.pdf
[37] AP: Arizona unconfirmed-citizenship voters double. apnews.com. https://apnews.com/article/voting-arizona-fontes-citizenship-ballot-election-f7b9aee24c58ee8a65d437c15c2d77a7
[38] Louisiana Illuminator: 390 found, 79 voted. lailluminator.com. https://lailluminator.com/2025/09/04/louisiana-election-investigation-finds-79-noncitizens-have-voted-since-1980s/
[39] Utah Lt. Governor: citizenship review summary. utah.gov. https://ltgovernor.utah.gov/wp-content/uploads/CITIZENSHIP-FULL-SUMMARY-2.pdf
[40] Idaho SOS McGrane: legislative report. idaho.gov. https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2025/standingcommittees/250317_ssta_0800AM-Minutes_Attachment_1.pdf
[41] NPR: noncitizen voting claims vs results (2025). npr.org. https://thin.npr.org/2025/07/30/nx-s1-5462836/noncitizen-voting-trump-ceir-review
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