Only U.S. citizens may vote in any election - federal, state, or local.

Why Is This Claim True?

Welcome!

This section is the factual registry for Claim #04-003-001. Every entry states one verifiable fact in a single sentence, cites the end source - the statute, court record, founding document, database, study, or dataset where the fact terminates - and identifies the sub-claim it bears on.

Arguments and interpretations belong in Q3 | Impact, cited to the parties who make them. No opinion piece is cited here as if it were a fact.

How we use commentary sources - We read serious commentary from across the spectrum. When a commentary piece cites a study, a court record, or a dataset, we find that actual source - if it exists - and register it here. The commentary itself, and the arguments it makes, are considered as we consider Q3 | Impact, cited to the writer with their perspective disclosed.

The three lanes - Evidence is numbered as follows:

• A-# | Affirming - facts a proponent would introduce to support this claim.

• D-# | Dissenting - facts an opponent would introduce to discredit this claim.

• N-# | Neutral - statutes, constitutional text, court holdings, official counts, agency records, and facts both sides might introduce.

Sub-claim key - SC-1 Voting is properly reserved to citizens, as both a benefit and a responsibility of citizenship.

• SC-2 Noncitizen voting is lawful today in a number of local jurisdictions, and noncitizens have been registered and have voted elsewhere by error or by fraud.

• SC-3 Noncitizen voting is small today, but it can expand through fraud or administrative failure to a scale that decides local elections.

• SC-4 A citizens-only law does not wrongly block eligible citizens.

• SC-5 The law can be enacted lawfully by one of three routes: By Congress for federal elections, by each state for its own state and local elections, or by constitutional amendment for all elections.

• SC-6 The benefit justifies the cost and effort.

Follow the links and judge the evidence for yourself. We provide our conclusions in the Q3 | Impact and Q4 | Solution sections of an issue.

Affirming Facts (A)

A-000009 | SC-2 - Federal voter registration relies on the applicant’s own attestation of citizenship under penalty of perjury, and election offices do not routinely verify citizenship against immigration databases at the point of registration.

Source: National Voter Registration Act of 1993 (U.S. Department of Justice); Bipartisan Policy Center (Feb. 2026).

Links: justice.gov · bipartisanpolicy.org

A-000013 | SC-3 - In February 2024, journalists documented an underground service, OnlyFake, selling realistic fake-ID images for $15 - advertised as neural-network generated at up to 20,000 documents per day - including a fabricated California driver’s license, complete with a signature, that passed the automated identity check of a major cryptocurrency exchange.

Source: 404 Media (Feb. 2024). Later forensic analysis questioned how much AI the service actually used; the cost, speed, and successful verification bypass are documented regardless. Also registered in Claim #04-003-002 and Claim #01-004-001.

Link: 404media.co

A-000014 | SC-3 - The U.S. Treasury’s Financial Crimes Enforcement Network issued an alert in November 2024 reporting an increase in suspicious-activity filings describing deepfake media - including identity documents created or altered with generative AI - used to circumvent identity verification at financial institutions.

Source: FinCEN Alert FIN-2024-Alert004 (Nov. 13, 2024). Also registered in Claim #04-003-002 and Claim #01-004-001.

Link: fincen.gov

A-000050 | SC-5, SC-6 - From 2018 through 2025, voters approved all 15 statewide constitutional amendments strengthening citizenship requirements for voting, averaging 73 percent support, and six more citizenship measures are on 2026 ballots, including Los Angeles’s November 2026 measure on local noncitizen voting.

Source: Ballotpedia News (July 2026); Spectrum News (June 2026).

Links: news.ballotpedia.org · spectrumlocalnews.com

A-000059 | SC-2, SC-3 - A software flaw in New Jersey’s motor-vehicle system registered roughly 6,600 noncitizens to vote between June 2023 and June 2024 - enrolling applicants even though they answered “no” to the citizenship question - and a preliminary state review found about 400 cast ballots in 2023-2024 elections, with no evidence any race was swayed; the error took a year to fix, was not disclosed until July 2026, and those registered remained on the rolls up to three years before removal began.

Source: Governor Sherrill announcement (July 21, 2026); NBC News; New Jersey Monitor. NOTE: Responsibility is contested and a federal investigation is open; figures may change.

Links: nbcnews.com · newjerseymonitor.com

A-000060 | SC-2, SC-3 - Oregon’s motor-voter system mistakenly registered more than 1,600 people who had not provided proof of citizenship, an error discovered in 2024 and traced to DMV staff mis-selecting document types; state reviews found about 17 of them had voting histories - several legally, having become citizens before voting - with roughly 9 potentially ineligible, and the governor paused automatic registration until an independent audit produced new rules in 2026.

Source: Oregon Secretary of State newsroom (Sept. 2024); Associated Press (Sept. 30, 2024); KOIN (Feb. 2026).

Links: apps.oregon.gov · wreg.com · koin.com

A-000151 | SC-1 - The Supreme Court, while holding that a blanket exclusion of aliens from state civil service was unconstitutional, stated that a state may deny to aliens the right to vote and the right to hold high public office.

Source: Sugarman v. Dougall, 413 U.S. 634, 648-649 (1973).

Link: supreme.justia.com

A-000152 | SC-1 - Upholding a citizenship requirement for public school teachers, the Supreme Court reasoned that the right to govern - of which the right to vote is the citizen’s share - is reserved to citizens.

Source: Ambach v. Norwick, 441 U.S. 68 (1979).

Link: supreme.justia.com

A-000153 | SC-1 - The Supreme Court upheld a state requirement that police officers be citizens, describing a class of governing functions - voting and officeholding among them - so bound up with the operation of the state as a political body that citizenship may be required.

Source: Foley v. Connelie, 435 U.S. 291 (1978).

Link: supreme.justia.com

A-000154 | SC-1 - Explaining how the President would be elected, Alexander Hamilton wrote that the electors would be chosen by their fellow citizens for that single purpose, and that guarding the election of the nation’s highest officer against foreign powers seeking to gain an improper ascendant in our councils was among the chief aims of the design.

Source: The Federalist No. 68 (Hamilton, 1788).

Links: avalon.law.yale.edu · Library of Congress full text

A-000155 | SC-1 - James Madison wrote that the definition of the right of suffrage - the right to vote - is very justly regarded as a fundamental article of republican government, and explained that the right to vote for members of the House was tied to each state’s own voter qualifications so that Congress could neither narrow nor enlarge the right to vote at will.

Source: The Federalist No. 52 (Madison, 1788).

Link: avalon.law.yale.edu

A-000156 | SC-1 - Answering the fear that Congress would manipulate elections, Alexander Hamilton wrote that the qualifications of the persons who may choose - the voters - and of those who may be chosen are defined and fixed in the Constitution and are unalterable by the legislature.

Source: The Federalist No. 60 (Hamilton, 1788).

Link: avalon.law.yale.edu

A-000157 | SC-1 - Asking directly who was to hold the right to vote for federal representatives, James Madison answered that the electors are to be the great body of the people of the United States - not the rich more than the poor, and not the learned more than the ignorant.

Source: The Federalist No. 57 (Madison, 1788). Scope: Madison’s point in this passage concerns wealth and class rather than citizenship; the entry is registered for its direct statement of who holds the right to vote.

Link: avalon.law.yale.edu

A-000158 | SC-1, SC-3 - The Supreme Court held that the right to vote can be denied by a debasement or dilution of the weight of a citizen’s vote just as effectively as by wholly prohibiting the free exercise of the franchise.

Source: Reynolds v. Sims, 377 U.S. 533, 555 (1964).

Link: supreme.justia.com

A-000159 | SC-4 - In the 2024 presidential election, 73.6 percent of the citizen voting-age population - about 174 million people - was registered to vote and 65.3 percent - about 154 million people - voted, one of the highest participation rates in modern American history.

Source: U.S. Census Bureau, Current Population Survey Voting and Registration Supplement, November 2024 (released Apr. 30, 2025). (Survey estimate, self-reported, weighted.)

Links: census.gov · census.gov

A-000160 | SC-4 - By the 2026 general election, 46 states and the District of Columbia offered at least one of the three modern registration methods - online registration in 43, same-day registration in 25, and automatic registration in 24 - up from seven states in 2000.

Source: Center for Election Innovation and Research, “The Expansion of Innovative Voter Registration Methods, 2000-2026” (current as of Feb. 25, 2026).

Link: electioninnovation.org

A-000161 | SC-4 - Federal law guarantees that any voter whose eligibility is questioned at the polls may cast a provisional ballot, which is counted if the voter is later determined to be eligible.

Source: 52 U.S.C. 21082 (HAVA sec. 302).

Link: law.cornell.edu

A-000162 | SC-4 - A nationwide analysis of voter files from 2008 through 2018 found that strict identification laws had no significant negative effect on registration or turnout, overall or for any racial group.

Source: Cantoni and Pons, “Strict ID Laws Don’t Stop Voters,” NBER Working Paper 25522, later published in the Quarterly Journal of Economics. Scope: The study measured identification requirements, not citizenship requirements. It is the closest measured evidence available on whether adding a requirement at the polls suppresses eligible turnout.

Link: nber.org

A-000163 | SC-5 - The Constitution has been amended four times to override state control of voter qualifications and protect the right to vote of citizens - by race in 1870, by sex in 1920, against poll taxes in 1964, and by age in 1971 - establishing that the amendment route is available for voting questions.

Source: U.S. Const. amends. XV, XIX, XXIV, XXVI.

Links: constitution.congress.gov · constitution.congress.gov · constitution.congress.gov · constitution.congress.gov

A-000164 | SC-5 - The Twenty-Sixth Amendment, which set a uniform national voting age for every election in every state, was ratified in 100 days - the fastest ratification of any amendment in American history.

Source: U.S. National Archives; USAFacts; Congressional Research Service Report 97-922.

Links: usafacts.org · everycrsreport.com

A-000165 | SC-5 - Congress holds legislative authority over the District of Columbia, and the House of Representatives has twice acted on it in this area: disapproving the District’s noncitizen voting law 260 to 162 in February 2023, and passing a repeal 266 to 148 in June 2025 with 56 Democrats joining the majority.

Source: U.S. Const. art. I, sec. 8, cl. 17; H.J. Res. 24 (118th Congress); H.R. 884 (119th Congress); Roll Call (Feb. 2023).

Links: congress.gov · rollcall.com · congress.gov

A-000166 | SC-6 - Between 1894 and 1926, voters considered twenty statewide measures to repeal or restrict noncitizen voting; seventeen were approved and three were defeated, and in each of the three states that first refused - Missouri, Nebraska, and Texas - voters approved a similar measure within the following several years.

Source: Alan H. Kennedy, “Voters in a Foreign Land: Alien Suffrage in the United States, 1704-1926,” Journal of Policy History 34(2): 245-275 (2022), as summarized in Ballotpedia News (July 2026).

Links: open-access thesis version · news.ballotpedia.org

A-000167 | SC-3 - In the same city where noncitizen ballots peaked at 72, Takoma Park’s certified 2024 results show the Ward 3 council seat decided by 61 votes after an instant runoff, 715 to 654, and the Ward 1 seat decided by 108 votes, 727 to 619 - margins at or below the documented noncitizen turnout.

Source: City of Takoma Park, certified results of the November 5, 2024 city election.

Links: certified results · takomaparkmd.gov

Dissenting Facts (D)

D-000053 | SC-2 - Georgia’s October 2024 citizenship audit of 8.2 million registered voters identified 20 noncitizen registrations, of whom nine had voted, most before the state’s 2012 verification upgrade.

Source: Georgia Secretary of State announcement (Oct. 2024), via Georgia Recorder and the Bipartisan Policy Center.

Links: georgiarecorder.com · bipartisanpolicy.org

D-000054 | SC-2 - Utah’s 2025–26 review of more than two million voter registrations found one confirmed noncitizen registration and zero noncitizen votes.

Source: State of Utah Citizenship Review Process (Jan. 22, 2026).

Links: drive.google.com · democracydocket.com

D-000056 | SC-2 - Ohio’s Secretary of State flagged 521 potential noncitizen voting cases between 2019 and September 2023, but a journalistic review found only one resulted in a voter-fraud charge, with most flags traced to clerical errors and DMV lag in recording naturalizations.

Source: Ohio Capital Journal (Sept. 27, 2023).

Link: ohiocapitaljournal.com

D-000168 | SC-1 - At least twenty-two states and territories gave noncitizens the right to vote during the nineteenth century - overwhelmingly declarant aliens who had filed a formal declaration of intent to naturalize.

Source: Jamin B. Raskin, “Legal Aliens, Local Citizens: The Historical, Constitutional and Theoretical Meanings of Alien Suffrage,” 141 U. Pa. L. Rev. 1391 (1993).

Link: digitalcommons.wcl.american.edu

D-000169 | SC-1 - Broader scholarly counts covering 1704 through 1926 put the total at roughly forty states and territories that gave noncitizens the right to vote at some point.

Source: Alan H. Kennedy, “Voters in a Foreign Land: Alien Suffrage in the United States, 1704-1926,” Journal of Policy History 34(2): 245-275 (2022), DOI 10.1017/S0898030622000021; Ron Hayduk, Democracy for All (2006). NOTE: The higher figure circulates chiefly through scholars who advocate restoring noncitizen voting, and the count is cumulative across 150 years rather than simultaneous.

Links: journal article of record · earlier open-access thesis version, William and Mary (2009)

D-000170 | SC-1 - Congress itself gave noncitizens the right to vote in the territories, granting declarant aliens the vote for territorial legislatures when it reenacted the Northwest Ordinance in 1789 and enfranchising declarant aliens in nine territories on condition of an oath to support the Constitution.

Source: Raskin, 141 U. Pa. L. Rev. 1391 (1993); Northwest Ordinance (1787), reenacted by the First Congress (1789).

Links: archives.gov · digitalcommons.wcl.american.edu

D-000171 | SC-1 - The Supreme Court observed in 1875 that citizenship has not in all cases been made a condition precedent to the enjoyment of the right of suffrage - that is, to the right to vote.

Source: Minor v. Happersett, 88 U.S. (21 Wall.) 162, 177 (1875).

Link: supreme.justia.com

D-000172 | SC-1 - Noncitizen voting ended state by state in the twentieth century, with the last repeals in South Dakota in 1918, Indiana, Texas, and Missouri in 1921, and Arkansas in 1926, making the citizens-only rule roughly a century old rather than a founding-era rule.

Source: Raskin, 141 U. Pa. L. Rev. 1391 (1993); Kennedy, Journal of Policy History (2022).

Links: digitalcommons.wcl.american.edu · scholarworks.wm.edu

D-000173 | SC-4 - Naturalized citizens - the group whose right to vote a citizenship check most directly touches - already vote at lower rates than native-born citizens: 41.4 percent compared with 53.4 percent in the 2022 election.

Source: U.S. Census Bureau, Current Population Survey Voting and Registration Supplement, November 2022 (May 2, 2023). (Survey estimate, self-reported, weighted.)

Link: census.gov

D-000174 | SC-5 - Of the many thousands of constitutional amendments introduced in Congress since 1789, only 33 were sent to the states and only 27 were ratified, and the average time to ratification was 617 days.

Source: USAFacts; Congressional Research Service Report 97-922; National Archives.

Links: usafacts.org · everycrsreport.com

D-000175 | SC-5 - The Equal Rights Amendment was ratified by 35 of the 38 states required and failed when the congressional deadline passed, demonstrating that broad support short of three-fourths of the states produces nothing.

Source: National Archives; Congressional Research Service.

Links: archives.gov · everycrsreport.com

D-000176 | SC-5 - No constitutional amendment has completed the ordinary proposal-and-ratification cycle since the Twenty-Sixth Amendment in 1971; the Twenty-Seventh, ratified in 1992, had been pending since 1789.

Source: Congressional Research Service Report 97-922; National Archives.

Link: everycrsreport.com

Neutral Record (N)

N-000047 | SC-2 - Federal law since 1996 makes it a crime for an alien to vote in any election for federal office, punishable by fine and up to one year of imprisonment.

Source: Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Pub. L. 104-208; 18 U.S.C. 611.

Links: law.cornell.edu · govinfo.gov

N-000049 | SC-5 - New York City’s 2021 law extending the right to vote in local elections to noncitizens was struck down as contrary to the state constitution, and the New York Court of Appeals affirmed 6 to 1 in March 2025.

Source: Fossella v. Adams, No. APL-2024-00033 (N.Y. Mar. 20, 2025) (Wilson, C.J., for a 6-1 Court), aff’g as modified 225 A.D.3d 98 (2d Dep’t 2024).

Link: law.justia.com

N-000051 | SC-5 - The SAVE Act, requiring documentary proof of citizenship to register for federal elections, passed the U.S. House in April 2025 and a revised version passed the House again in February 2026, but it has not passed the Senate and is not law.

Source: Congress.gov, H.R. 22 (119th Congress); NBC News (Feb. 2026).

Links: congress.gov · nbcnews.com

N-000052 | SC-5 - A March 2025 executive order directing proof of citizenship on the federal registration form was challenged by nineteen states, had its major provisions blocked during 2025, and was permanently blocked in January 2026 by a federal judge who found the president lacks authority to unilaterally alter election procedures.

Source: Executive Order of Mar. 25, 2025 (Federal Register); Congressional Research Service, LSB11368.

Links: federalregister.gov · congress.gov

N-000063 | SC-1 - The Supreme Court has described voting as “a fundamental political right, because preservative of all rights.”

Source: Yick Wo v. Hopkins, 118 U.S. 356, 370 (1886).

Link: supreme.justia.com

N-000146 | SC-5 - The Supreme Court held that Congress may not compel state officers to administer a federal regulatory program.

Source: Printz v. United States, 521 U.S. 898 (1997).

Link: supreme.justia.com

N-000177 | SC-5 - The Constitution provides that those who vote for members of the House shall have the qualifications requisite for electors of the most numerous branch of the state legislature, and the Seventeenth Amendment applies the same borrowed standard to the Senate.

Source: U.S. Const. art. I, sec. 2, cl. 1; amend. XVII.

Links: constitution.congress.gov · constitution.congress.gov

N-000178 | SC-5 - The Constitution directs each state legislature to determine the manner of appointing presidential electors.

Source: U.S. Const. art. II, sec. 1.

Link: constitution.congress.gov

N-000179 | SC-5 - The Elections Clause provides that the times, places, and manner of holding congressional elections shall be prescribed in each state by the legislature, while reserving to Congress the power to make or alter such regulations.

Source: U.S. Const. art. I, sec. 4.

Link: constitution.congress.gov

N-000180 | SC-5 - Article V provides the two routes for amending the Constitution: proposal by two-thirds of both houses of Congress or by a convention called on the application of two-thirds of the state legislatures, followed in either case by ratification by three-fourths of the states.

Source: U.S. Const. art. V.

Link: constitution.congress.gov

N-000181 | SC-1 - The Constitution gives Congress the power to establish an uniform Rule of Naturalization - the process by which a foreigner becomes a citizen and gains the right to vote.

Source: U.S. Const. art. I, sec. 8, cl. 4.

Link: constitution.congress.gov

N-000182 | SC-1 - All persons born or naturalized in the United States and subject to its jurisdiction are citizens of the United States and of the state in which they reside, and federal statute sets out the classes of persons who are citizens at birth.

Source: U.S. Const. amend. XIV, sec. 1; 8 U.S.C. 1401.

Links: constitution.congress.gov · law.cornell.edu

N-000183 | SC-1 - Each of the five constitutional provisions that protects voting phrases the protection as the right of citizens of the United States to vote: the Fourteenth Amendment Section 2, the Fifteenth, the Nineteenth, the Twenty-Fourth, and the Twenty-Sixth.

Source: U.S. Const. amends. XIV, sec. 2; XV; XIX; XXIV; XXVI.

Links: constitution.congress.gov · constitution.congress.gov · constitution.congress.gov

N-000184 | SC-1 - The Declaration of Independence states that governments derive their just powers from the consent of the governed, and lists among the grievances against the King that he obstructed the laws for naturalization of foreigners.

Source: Declaration of Independence (1776), National Archives transcript.

Link: archives.gov

N-000185 | SC-2 - Unlawful voting makes an alien deportable and inadmissible, and a false claim of United States citizenship made in order to register or vote carries separate immigration and criminal penalties.

Source: 8 U.S.C. 1227(a)(6); 8 U.S.C. 1182(a)(10)(D) and (a)(6)(C)(ii); 18 U.S.C. 1015(f).

Links: law.cornell.edu · law.cornell.edu · law.cornell.edu

N-000186 | SC-2 - The National Voter Registration Act of 1993 created the federal mail voter registration form and requires applicants to attest to United States citizenship under penalty of perjury.

Source: National Voter Registration Act of 1993, 52 U.S.C. 20501 et seq. (U.S. Department of Justice).

Link: justice.gov

N-000187 | SC-2 - The Help America Vote Act of 2002 required each state to maintain a single computerized statewide voter registration list.

Source: 52 U.S.C. 21083 (HAVA sec. 303).

Link: law.cornell.edu

N-000188 | SC-5 - When Congress lowered the voting age to 18 for all federal, state, and local elections by statute in 1970, the Supreme Court held that Congress could do so only for federal elections, and the country responded by amending the Constitution the following year.

Source: Oregon v. Mitchell, 400 U.S. 112 (1970); U.S. Const. amend. XXVI.

Link: supreme.justia.com

N-000189 | SC-2, SC-5 - As of November 2025, no state constitution expressly permitted noncitizens to vote in state or local elections, and eighteen states expressly prohibited it.

Source: Ballotpedia, “Laws permitting noncitizens to vote in the United States.”

Link: ballotpedia.org

N-000190 | SC-5, SC-6 - Six statewide citizenship-voting measures are on 2026 ballots: Alaska, Arizona, Arkansas, Kansas, South Dakota, and West Virginia.

Source: Ballotpedia News (July 2026).

Link: news.ballotpedia.org

N-000191 | SC-2 - The District of Columbia extended the right to vote in local elections to noncitizen residents under the Local Resident Voting Rights Amendment Act, which took effect in 2023.

Source: D.C. Law 24-242.

Link: code.dccouncil.gov

N-000192 | SC-2 - Roughly eleven Maryland municipalities allow noncitizen residents to vote in local elections, with Takoma Park the earliest, since 1992, and several using a separate ballot to keep local and higher contests apart.

Source: Ballotpedia; NPR (Nov. 2022).

Links: ballotpedia.org · npr.org

N-000193 | SC-2 - Three Vermont cities allow noncitizen residents to vote in local elections: Montpelier and Winooski beginning in 2021, and Burlington in 2023.

Source: Ballotpedia, “Laws permitting noncitizens to vote in the United States.”

Link: ballotpedia.org

N-000194 | SC-2 - San Francisco permits noncitizen parents, guardians, and caregivers of city children to vote in Board of Education elections under Proposition N of 2016, and Oakland approved a comparable measure in 2022 that remained unimplemented as of 2026.

Source: San Francisco Standard (Aug. 2023); Ballotpedia, Oakland Measure S (2022); Oaklandside (Nov. 2024).

Links: sfstandard.com · ballotpedia.org · oaklandside.org

N-000195 | SC-5 - Village voters in Yellow Springs, Ohio approved a charter amendment in the March 2020 primary allowing noncitizens to vote in local elections, and it was never implemented after the Ohio Secretary of State directed the Greene County Board of Elections to reject noncitizen registrations and to exclude any such votes from the canvass; the village chose not to challenge the directive in court.

Source: Ohio Secretary of State, directive to the Greene County Board of Elections and press release (July 30, 2020); Ballotpedia.

Links: ohiosos.gov · ballotpedia.org

N-000196 | SC-6 - Voters in Santa Ana, California rejected Measure DD in November 2024 by about 60 percent to 40 percent, declining to extend the right to vote in city elections to noncitizen residents in a city where roughly a quarter of residents are noncitizens.

Source: Orange County Registrar of Voters results, as reported by LAist (Nov. 2024); Ballotpedia.

Links: laist.com · ballotpedia.org

N-000197 | SC-5 - The Los Angeles City Council voted 10 to 5 in June 2026 to place a charter amendment extending the right to vote in city and school district elections to noncitizens on the November 2026 ballot, then pulled the measure in July 2026 and returned it to committee, so it will not appear on that ballot.

Source: Spectrum News (June 2026); Los Angeles City Council actions (July 2026).

Links: spectrumlocalnews.com · Council File: 26-0638 -

N-000198 | SC-1 - The Supreme Court held that citizenship does not by itself confer the right to vote and that the Constitution did not add the right to vote to the privileges of national citizenship.

Source: Minor v. Happersett, 88 U.S. (21 Wall.) 162 (1875).

Link: supreme.justia.com

N-000199 | SC-5 - The Supreme Court held that the right to vote is not derived from the United States but is conferred by the state, which may set reasonable qualifications for its exercise.

Source: Pope v. Williams, 193 U.S. 621 (1904).

Link: supreme.justia.com

N-000200 | SC-1 - The Supreme Court held that state classifications based on alienage are inherently suspect and subject to close judicial scrutiny, a holding that makes the political function exception in A-000151 through A-000153 the operative doctrine for the right to vote.

Source: Graham v. Richardson, 403 U.S. 365 (1971).

Link: supreme.justia.com

N-000201 | SC-1 - The Supreme Court extended the political function exception to probation officers, restating that a state may exclude aliens from positions and functions that go to the heart of representative government.

Source: Cabell v. Chavez-Salido, 454 U.S. 432 (1982).

Link: supreme.justia.com

N-000202 | SC-5 - The Supreme Court held that a state may not unilaterally add a documentary proof-of-citizenship requirement to the federal voter registration form, while reaffirming that the states rather than Congress set voter qualifications.

Source: Arizona v. Inter Tribal Council of Arizona, 570 U.S. 1 (2013).

Link: supreme.justia.com

N-000203 | SC-5 - The California Constitution provides that a United States citizen 18 years of age and resident in the state may vote, using permissive rather than exclusive language.

Source: Cal. Const. art. II, sec. 2(a).

Link: law.justia.com

N-000204 | SC-2 - A peer-reviewed demographic modeling study estimated the unauthorized immigrant population at 22.1 million as of 2016, with a 95 percent range of 16.2 million to 29.5 million and a deliberately conservative lower bound of 16.7 million, against the conventional survey-based figure of 11.3 million.

Source: Fazel-Zarandi, Feinstein, and Kaplan, “The number of undocumented immigrants in the United States: Estimates based on demographic modeling with data from 1990 to 2016,” PLOS ONE (Sept. 21, 2018). NOTE - DISPUTED FROM BOTH DIRECTIONS: The Migration Policy Institute and the Center for Immigration Studies each published disagreements with the method, Pew Research Center retained its 11 million estimate, and PLOS ONE carries a formal published comment disputing the article. SCOPE: The study counts unauthorized immigrants only, a subset of the noncitizen population this claim addresses, and it measures population size rather than voting.

Links: journals.plos.org · MIT Sloan summary · Published dispute

N-000205 | SC-2 - As of 2024, an estimated 50.2 million foreign-born residents lived in the United States - about 14.8 percent of the national population - a category that includes naturalized citizens, lawful permanent residents, temporary and humanitarian migrants, and unauthorized migrants alike, while Pew Research Center counted nearly 24 million naturalized citizens of voting age.

Source: U.S. Census Bureau, American Community Survey 2024 one-year estimates, Table DP02, via Congressional Research Service Report R48940; Pew Research Center (Sept. 2024). NOTE: The noncitizen remainder - roughly 26 million people of all ages - is arithmetic derived from these two published figures, not a single published Census figure, and should be presented as derived.

Links: congress.gov · pewresearch.org

N-000206 | SC-3 - Noncitizen ballots reached their documented peak in Takoma Park, Maryland at 72 votes in the 2017 mayoral election out of 2,520 ballots cast - about three percent of that municipal electorate - and the city stopped collecting the data after 2017.

Source: City of Takoma Park records provided to PolitiFact (Oct. 2024). NOTE: Both sides read this entry. A proponent notes that three percent of a municipal electorate exceeds the margin in many local contests; an opponent notes that the absolute number is 72.

Links: · City records and the 2,520-ballot denominator · · The charter provision that permits it (Article VI, Section 601) · codepublishing.com

N-000207 | SC-3 - Where noncitizen voting is lawful, participation has been very low: The D.C. Board of Elections confirmed 113 noncitizens cast ballots - for local offices only - in the District’s June 4, 2024 primary, and in Vermont’s March 2024 Town Meeting Day elections, 62 of 102 registered noncitizens voted in Burlington, 13 of 18 in Montpelier, and 11 of 61 in Winooski.

Source: D.C. Board of Elections statement (Aug. 2024); Vermont Public/PBS (Apr. 2024).

Links: DCBOE confirmation of the count · Vermont counts and registrants · Background and D.C. registration figures

N-000208 | SC-5 - Seven constitutional amendments - the Thirteenth, Fourteenth, Fifteenth, Nineteenth, Twenty-Third, Twenty-Fourth, and Twenty-Sixth - close with materially the same enforcement sentence: “The Congress shall have power to enforce this article by appropriate legislation.”

Source: U.S. Constitution, amend. XIII § 2; XIV § 5; XV § 2; XIX; XXIII § 2; XXIV § 2; XXVI § 2.

Link: constitution.congress.gov

Sub-Claim Cross-Reference Matrix

Legend:

• Built from the sub-claim tags in the registry.

• Three dashes means no direct factual entry in that lane, although indirect facts may be presented under other sub-claims.

• An empty lane is itself a finding. Where a lane is empty, the claim rests on reasoning rather than measured fact at that point, and Q3 | Impact must say so.

What the matrix shows. Six findings follow directly from the lanes, and each becomes work for Q3 | Impact:

• SC-1 is the contested ground. Eight affirming entries face five dissenting entries, and the dissent is documentary rather than speculative. The constitutional text, the Federalist Papers, and the political function cases carry the affirming side; the record of noncitizen voting from 1704 to 1926 - including the Supreme Court’s own acknowledgment of it in D-000171 and Congress’s role in the territories in D-000170 - carries the dissent.

• SC-2 is established, and the record keeps growing. That noncitizens may lawfully vote in some local elections today is not in dispute at all - N-000191 through N-000194 establish it from published law. New instances of noncitizens reaching the rolls by error keep surfacing: Oregon in 2024, New Jersey in 2026.

What is contested is how much, and there the two sides measure different things. The affirming entries count system failures - what one software error in New Jersey and one procedural error in Oregon put on the rolls. The dissenting entries count audit yields - what Georgia, Utah, and Ohio found after searching. Both can be true at once, and Q3 must not present them as rival estimates of the same quantity.

Ohio is the caution in both directions: 521 flagged and one charged means the detection systems produce mostly false positives, which overstates the problem and also corrupts the data used to measure it.

• SC-3 is a claim about risk, not about today. The sub-claim concedes the present scale and asserts what could follow, so the small current numbers in N-000207 confirm the premise rather than refute it. Three things carry it.

• Scale can appear without any attacker: a single software error put roughly 6,600 noncitizens on New Jersey’s rolls and about 400 voted (A-000059), and Oregon’s motor-voter system added more than 1,600 (A-000060).

• Identity fraud is cheap and getting cheaper - $15 documents that defeat automated verification (A-000013), and a federal alert on AI-generated identity documents defeating verification at banks (A-000014).

• Local margins are small enough to matter: Takoma Park’s 2024 Ward 3 seat was decided by 61 votes in the same city where noncitizen ballots peaked at 72 (A-000167, N-000206).

A-000158, Reynolds v. Sims, supplies the legal frame - a citizen’s vote can be denied by dilution as effectively as by prohibition, a harm that does not require proving an outcome changed.

What no entry shows is an American election whose outcome was changed by noncitizen voting. Q3 must argue this as prevention, not as history.

• SC-4 favors the claim. Once the question is narrowed to whether a citizens-only law blocks eligible citizens, the answer is that participation is high and access is expanding. The single dissenting entry, D-000173, does not show blocking; it shows that naturalized citizens vote less often for reasons this law does not create.

• SC-5 is contested on both sides. The affirming case is that the Constitution has been amended four times to set voter qualifications, once in 100 days, and that voters have approved fifteen state amendments in eight years.

The dissenting case is that amendments almost never pass: 27 of 33 sent to the states, none by the ordinary route since 1971, and the Equal Rights Amendment failed three states short.

N-000188 is the pivot - the last time the country tried to set a uniform voter qualification for every election by statute, the Court struck it down as to state and local elections and the country amended the Constitution instead.

• SC-6 evidence is thin. Two affirming entries and two neutral entries, plus the polling gap noted at the end of this section. But SC-6 is largely derivative: if the sub-claims above hold - the vote belongs to citizens, noncitizens are on the rolls, the scale could grow to decide local races, and honest voters are not blocked - then a rule costing little and asking nothing new of the ordinary voter is reasonable on the record already assembled.

A-000166 adds the closest thing to a public verdict: The question was put to voters twenty times between 1894 and 1926 and answered the same way seventeen times, which is a record of votes rather than opinion.

A note on the scope of SC-4 This claim states who may vote. It does not specify how a person proves citizenship. SC-4 therefore asks one question only: Does a citizens-only law wrongly block eligible citizens from voting? Evidence about the cost or difficulty of obtaining documents belongs to the claims that build the proof - Claim #04-003-002 and Claim #04-003-004 - and is registered there, not here.

Facts held out of this registry Three categories were considered and excluded, so the reader knows the omission was deliberate:

• California Proposition 39. It requires identification and citizenship verification, not a change in who may vote. Verification is not eligibility. It is registered under Claim #04-003-002 and Claim #04-003-004.

• Documentary burden evidence. Survey estimates of how many adults lack current identification, and studies of what obtaining documents costs, bear on how citizenship is proven rather than on who may vote. They are registered under Claim #04-003-002 and Claim #04-003-004.

• The consent-of-the-governed argument. That noncitizen residents pay taxes and live under local ordinances is a genuine argument against this claim, but it is an argument, not a fact. It is developed in Q3 | Impact and cited to the parties who make it.

Known gap - We have not identified reliable national polling that tests this claim as written: A citizens-only law reaching local elections specifically. Polling on the general proposition is abundant; polling on the local question, where the dispute actually lies, is thin. The ballot-measure record in A-000050 is the better available measure, and it measures votes rather than opinion.

Evidence numbering - The lane letter is not part of the number. It records where this claim places the fact. The same fact may sit in a different lane in a different claim, and 5 of the 15 shared facts do.

• The digits encode nothing. Not source type, not origin claim, not date. They are a plain sequence.

• Entries are listed in ascending permanent-number order within each lane. The order carries no argumentative weight.

• As we continue to expand our library of issues, some facts will be listed in multiple claims, and sometimes sit in different lanes because of how they relate to each claim.

• Fact numbers are permanent and global. Once assigned, a six-digit number is never reused or reassigned, and the same fact carries the same number in every claim where it appears. This registry holds 73 facts: 58 first registered here (000151-000208) and 15 already registered in earlier claims.

• Sources can be repeated - one source may support multiple entries in any lane.

• Every fact must include a link to the source; a fact that cannot be traced to a primary source does not enter the registry.

A note on facts that change lanes. Among the shared facts, A-000059 and A-000060 - the New Jersey and Oregon motor-vehicle registration failures - are Affirming here, because this claim asks whether a citizens-only rule holds without verification, and these are two documented instances where it did not.

In Claim #04-003-002 the same facts are Neutral Record, where they describe how a registration system behaved. The facts have not changed and neither has our reading of them. What changed is the question each claim asks.

• Sub-claim tags use SC-1 through SC-5, matching Q1 | Meaning, Section IV.

DISCLAIMER

Listing evidence in one of these three lanes does not mean we endorse it as true. We verify two things: The lane - Affirming, Dissenting, Neutral - and that each source states the fact we summarize. Upon close inspection, you may find the evidence claimed is strong, mixed, or weak.

It would imply bias for us to exclude perspectives that claim a reasonable factual basis, so we include the full breadth. However, in reality, studies rest on assumptions that can be biased; surveys are estimates, not full counts; and people on all sides of an issue do research with the intent to prove themselves right.

A source may support multiple entries, but where one link serves several facts, we attempt to have each entry link to the specific section. Tertiary sources are used only where no primary source exists or where the tertiary source is itself the compiler.

Source Index Alphabetical list of all sources cited in the registry. Sources are unnumbered; the permanent identifiers belong to facts, not sources.

404 Media · Ambach v. Norwick (U.S. 1979) · American University Washington College of Law (Digital Commons) · Arizona v. Inter Tribal Council of Arizona (U.S. 2013) · Associated Press · Ballotpedia / Ballotpedia News · Bipartisan Policy Center · Cabell v. Chavez-Salido (U.S. 1982) · California Constitution · Cambridge University Press (Journal of Policy History) · Alan H. Kennedy, Journal of Policy History · Cantoni and Pons (NBER) · Center for Election Innovation and Research · Center for Immigration Studies · CNN · Congress.gov · Congressional Research Service · Declaration of Independence · Democracy Docket · District of Columbia Council · Federal Register · FinCEN (U.S. Treasury) · The Federalist (Nos. 52, 57, 60, 68) · Foley v. Connelie (U.S. 1978) · Fossella v. Adams (N.Y. Ct. App. 2025) · Georgia Recorder · Georgia Secretary of State · Graham v. Richardson (U.S. 1971) · KOIN · LAist · Library of Congress · Migration Policy Institute · Minor v. Happersett (U.S. 1875) · MIT Sloan School of Management · National Archives · NBC News · New Jersey Monitor · New Jersey Office of the Governor · New York Court of Appeals · Northwest Ordinance (1787) · NPR · PBS · Oaklandside · Ohio Capital Journal · Ohio Secretary of State · Orange County Registrar of Voters · Oregon Secretary of State · Oregon v. Mitchell (U.S. 1970) · Pew Research Center · PolitiFact · PLOS ONE (Fazel-Zarandi, Feinstein, and Kaplan) · Pope v. Williams (U.S. 1904) · Printz v. United States (U.S. 1997) · Jamin B. Raskin, University of Pennsylvania Law Review · Reynolds v. Sims (U.S. 1964) · Roll Call · San Francisco Standard · Spectrum News · City of Takoma Park · Sugarman v. Dougall (U.S. 1973) · U.S. Census Bureau · U.S. Code (8 U.S.C. 1182, 1227, 1401; 18 U.S.C. 611, 1015; 52 U.S.C. 20501, 21082, 21083) · U.S. Constitution · U.S. Department of Justice · USAFacts · Utah Office of the Lieutenant Governor · William and Mary ScholarWorks · Yick Wo v. Hopkins (U.S. 1886)