A Growing Affront to U.S. Democracy

Published August 2026

Introduction

“I am a Black voter and a veteran, and I grew up in an era of segregation when it was common for public officials and certain members of our communities to make it difficult for us to vote. Having to deal with these kinds of obstacles still today is both discouraging and aggravating, and makes it seem like we should just give up. . . . I wonder if it is even worth trying to vote again given the trouble that the voter challenge has caused me.”

—Gamaliel Warren Turner Sr., a registered Georgia voter whose voting eligibility was challenged by the organization True the Vote ahead of Georgia’s U.S. Senate runoff election in 2021¹

Six decades ago, in 1965, the Voting Rights Act (VRA)² was signed into law. The VRA’s goal was to eliminate racial discrimination in voting policies and “to enforce the Fifteenth Amendment to the Constitution of the United States,”³ which prohibits denying the right to vote based on a person’s race or skin color.⁴ The VRA outlawed discriminatory, Jim Crow-era barriers such as literacy tests, poll taxes, and voter harassment or intimidation.⁵ In doing so, the enactment of the VRA was a testament to the United States’ commitment to removing the obstacles that Black people and other marginalized groups continued to experience when exercising their right to vote.

Congress specifically designed Section 2 of the VRA to acknowledge discrimination, including structural racism, and to provide a safeguard against voting laws that harmed Black voters and other marginalized voters.⁶ On paper, Section 2 prohibits states from using any “standard, practice, or procedure” that “results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color.”⁷ Until recently, Section 2 of the VRA was a fundamental law that could protect voters from discriminatory voting systems.⁸ However, as Associate Justice of the U.S. Supreme Court Elena Kagan described in her 2026 dissent in Louisiana v. Callais, Section 2 is now “all but a dead letter.”⁹ Before Callais, the Court’s 2021 decision in Brnovich v. Democratic National Committee had already curtailed Section 2 by holding that Arizona’s racially discriminatory laws did not violate the VRA.¹⁰ As a result, the Court created new burdens to challenges of discriminatory voting laws, significantly limiting Section 2’s scope.¹¹ Brnovich was a death knell for the VRA’s protections that would have applied to voter challenges, which have lately become an increasing problem.

In recent years, self-proclaimed “election integrity” organizations and individuals who purport to be concerned about voter fraud have used mass voter challenges to disrupt elections. Mass voter challenges involve disputing a large number of voters’ eligibility, targeting hundreds or thousands of individuals in one filing. The rise of mass voter challenges underscores the importance of defending the right of all eligible voters to freely cast ballots.

For example, in December 2020, the organization True the Vote filed a mass voter challenge in Georgia targeting approximately 364,000 people—nearly five percent of Georgia’s active voters. The challenge was filed just days before the state’s January 5, 2021, runoff election for both of its U.S. Senate seats.¹² Notably, True the Vote’s mass challenge came shortly after the nation saw historic turnout rates in the November 3, 2020, presidential election,¹³ including new turnout records for Black voters.¹⁴ Voting rights advocates were concerned about True the Vote’s challenge due to its proximity to the runoff election and the scant evidence provided.

In response, Fair Fight, Inc., a Georgia-based nonprofit founded by Stacey Abrams that fights for free and fair elections, filed a lawsuit. In Fair Fight, Inc. v. True the Vote, Fair Fight asked the U.S. District Court for the Northern District of Georgia to put an end to True the Vote’s mass voter challenge as they believed it was a voter suppression tactic.¹⁵ First, Fair Fight disputed the evidence on which True the Vote based their challenge. Using information from the U.S. Postal Service’s National Change of Address registry, True the Vote claimed that if voters changed their mailing address, this meant that they no longer lived in Georgia and were therefore ineligible to vote in the state. However, Fair Fight contended that this information alone was insufficient to prove that a person was ineligible to vote. Second, Fair Fight argued that True the Vote’s effort to remove approximately 364,000 names from the voter rolls so close to a federal election violated federal law, such as the National Voter Registration Act of 1993 (NVRA), which requires any systematic removal of voters from the voter rolls to occur at least ninety-one days before a federal election.¹⁶ The U.S. District Court for the Northern District of Georgia found that True the Vote’s mass challenge did not violate Section 11(b) of VRA, which outlaws voter intimidation tactics.¹⁷ Although the District Court did not halt True the Vote’s challenge, its opinion did reiterate that mass voter challenges can violate Section 11(b) of the VRA.¹⁸

True the Vote’s effort in Georgia is just one of many recent examples of a mass voter challenge. In response to historic voter turnout during the 2020 presidential election cycle, mass voter challenges became a key voter intimidation and suppression strategy to remove eligible voters from the rolls. Furthermore, original research conducted by the Legal Defense Fund (LDF) suggests that these challenges may have disproportionately impacted Black voters in Georgia.

This Brief argues that mass voter challenges unnecessarily burden the voters who are challenged as well as election workers, while having a chilling effect on other voters. All Americans should therefore be concerned by these threats to democracy. The first section of this Brief situates mass voter challenges from 2020 to 2024 within a larger history of voter suppression tactics in the United States. The second section describes the contemporary harms of mass voter challenges. Next, the Brief presents case studies from Georgia and Florida from 2020 through 2024 to illuminate how organizations and individuals use anti-democracy laws and mass voter challenges as voter suppression tactics. The Brief concludes with policy recommendations to curtail the negative impacts that mass voter challenges have on democracy.

Part I

MASS VOTER CHALLENGES: A NEW CHAPTER IN THE HISTORY OF VOTER SUPPRESSION

How Voter Suppression Harms American Democracy

Social scientists and legal scholars have long studied how voter suppression tactics in U.S. elections pose great risks to American democracy—and mass voter challenges are one of the latest voter suppression trends.¹⁹ Taken together, various forms of voter suppression throughout U.S. history reveal that the nation has never fully lived up to the promise of a functioning, multi-racial democracy.

Voter suppression tactics disproportionately target voters of color,²⁰ and research suggests that such suppression contributes to the growing gap in voter turnout by race.²¹ In a 2023 article, political scientists Dr. Luis Ricardo Fraga, Dr. Ricardo Ramírez, and Dr. Bernard L. Fraga argue that voter suppression has been and continues to be one of the greatest weaknesses of American democracy.²² They further argue that the recent rise in voter suppression tactics has its origins in concerns about major national demographic shifts.²³ In short, a healthy democracy ensures that members of all racial groups can exercise their right to vote. However, the United States has never upheld true democratic principles because it has historically relied on voter suppression to exclude certain groups—particularly Black people—from the political process. Similarly, legal scholar Renalia DuBose argues that voter suppression is an American legacy.²⁴

A truthful and comprehensive history of voting rights in the United States must acknowledge both the slow but progressive expansion of voter eligibility as well as the ongoing fight to ensure that eligible voters do not experience suppression. Significant changes occurred with the ratification of the Reconstruction Amendments between 1865 and 1870ⁱ: the Fourteenth Amendment established that Black people born in the United States were citizens and that all persons are entitled to equal protection under the law,²⁵ and the Fifteenth Amendment extended the right to vote to citizens regardless of “race, color, or previous condition of servitude.”²⁶

While the Fifteenth Amendment paved the way for all male citizens regardless of race to vote, voter suppression tactics made it difficult for eligible Black male voters to exercise this right. Around the same time that the Reconstruction Amendments were ratified, Jim Crow laws were introduced across the South and reinforced a racial caste system.²⁷ Under that system, political officials altered state constitutions to effectively deny many Black men their right to vote.²⁸ These state constitutions contained provisions about poll taxes, literacy tests, grandfather clauses, and other forms of intimidation and suppression that prohibited Black men from exercising their newly acquired right to vote.²⁹

Historical Voter Suppression Tactics

All-white primaries

All-white primaries: Primary elections are held to determine which candidates will appear on the ballot in a general election. Although primaries are common across the country today, they were not widespread until the 1870s.³⁰ In the years following Reconstruction, Black people in the U.S. South experienced disenfranchisement, and politicians established all-white primaries that excluded anyone who was not white from participating.³¹ Such exclusionary primaries would not be struck down until the 1944 U.S. Supreme Court decision in Smith v. Allwright,³² which was argued by LDF founder Thurgood Marshall.³³

Grandfather clauses

Grandfather clauses: Grandfather clauses allowed individuals to be exempt from voting eligibility requirements if their ancestors were eligible to vote. After Reconstruction, many Southern states used grandfather clauses to prevent Black people from voting—even though the Fifteenth Amendment outlawed denying a citizen the right to vote based on their “race, color, or previous condition of servitude.” For example, in the early 1900s, the Oklahoma State Constitution had a literacy requirement attached to voting eligibility, but residents could be exempt from that requirement if their ancestors could vote before January 1, 1866.³⁴ Since many Black people’s grandfathers were enslaved and therefore could not vote at that time, the grandfather clause was of no benefit to them. Instead, it removed the literacy requirement for white people who were descendants of voters. Grandfather clauses were deemed unconstitutional in the 1915 U.S. Supreme Court decision in Guinn v. United States.³⁵

Literacy tests

Literacy tests: Literacy tests were exams that some states, mainly those in the South, administered after the ratification of the Reconstruction Amendments. Research shows that these tests prevented large swaths of marginalized voters, including Black people, from voting.³⁶ Literacy tests were a prerequisite to voting and supposedly assessed whether someone could read and write in English. However, the tests were often long and complicated, and policymakers designed the tests to be unfair even to a literate person. For example, one edition of Alabama’s literacy test asked, “Does enumeration affect the income tax levied on citizens in various states?” as one of the sixty-eight questions a prospective voter had to answer.³⁷ The VRA ended the use of literacy tests in 1965.³⁸

Poll taxes

Poll taxes: After Reconstruction, many Southern states required eligible voters to pay a fee, also known as a poll tax, before voting. Although the Fifteenth Amendment expanded voting eligibility to Black men, policymakers implemented poll taxes as a voter suppression tool to make it harder for poor and Black people to vote.³⁹ From 1889 to 1910, eleven Southern states had poll taxes.⁴⁰ For example, Alabama’s poll tax was $1.50, which amounted to one week’s pay for some low-wage workers.⁴¹ This made it difficult for low-wage workers, especially formerly enslaved people, to pay the tax and vote. Poll taxes were thus extremely cost-prohibitive and racially discriminatory. The ratification of the Twenty-Fourth Amendment in 1964 prohibited poll taxes in federal elections.⁴² Poll taxes were not outlawed in state and local elections until the 1966 U.S. Supreme Court decision in Harper v. Virginia Board of Elections.⁴³

The Racially Discriminatory Impact of Voter Challenge Laws

Historically, policymakers implemented voter suppression tactics in response to enfranchising efforts that gave voters of color, and specifically Black voters, greater access to the ballot box. As explained later in this Brief, mass voter challenges today are similarly a response to growing turnout among voters of color.

Although mass voter challenges have become more common in recent years, voter challenge laws have a long history in the United States and can be traced back to as early as the Revolutionary War.⁴⁴ One voter challenge law from 1781 allowed New York residents to file challenges against those suspected of being loyal to Great Britain.⁴⁵ Several states also enacted voter challenge laws at the beginning of Reconstruction.⁴⁶ In recent years, there has been a resurgence of voter challenges under these longstanding laws. For example, Georgia’s voter challenge statutes have existed since at least 1933,⁴⁷ but they were largely unutilized before 2020.⁴⁸ Lately, individuals and organizations have used voter challenge laws to discriminate against voters of color and have gone beyond the scope of curtailing voter fraud, which is an exceedingly rare phenomenon.⁴⁹

As with other voter suppression tactics, people have often used voter challenge laws of the past and present to target voters of color even though the laws are facially race neutral (meaning that the laws do not contain any language directly stating that voters of color are ineligible to vote). A 2012 report from the Brennan Center for Justice found that following the U.S. Civil War, some states put forth or amended voter challenge laws with the intent to hinder the political participation of newly enfranchised voters of color, most of whom were Black men.⁵⁰ For example, Florida’s challenge statute was part of the state’s election laws as early as 1845.⁵¹ At the time, Florida’s election laws defined voters as free white men ages twenty-one years and older who were U.S. citizens, had a home in Florida, and had served in the military or were exempt from serving by law. If someone filed a challenge questioning a person’s eligibility to vote, election inspectors would investigate the claim.⁵² After the Fifteenth Amendment granted Black men the right to vote, Florida passed several laws in 1877 to suppress Black voter turnout.⁵³ One such law required every challenged voter to provide two witnesses from their district who were each known to at least two polling place officials to vouch for their eligibility to vote.⁵⁴ The Brennan Center for Justice noted that while the text of this law was race neutral, this requirement placed Black male voters at a disadvantage because Florida was racially segregated, and thus finding witnesses who knew polling place officials was difficult.⁵⁵

In another instance of using voter challenge laws to disenfranchise Black voters, Eugene Talmadge orchestrated challenges against Black voters during his Georgia governor campaign in 1946. After the ruling in Smith v. Allwright outlawed all-white primaries in 1944, groups such as the National Association for the Advancement of Colored People (NAACP) led successful grassroots campaigns to register Black people to vote across the South. In Georgia, the number of Black residents who were registered to vote exploded: there were approximately 20,000 registered Black voters in 1940 and nearly 200,000 in 1946.⁵⁶ In response to the abolition of Georgia’s all-white primary elections, Talmadge alleged that Black voters were not registered correctly and therefore could not vote in the primaries.⁵⁷ He pointed to race-neutral language in the Code of Georgia, which at the time stated that voters could be challenged if they could not correctly read, write, or interpret any part of the U.S. Constitution or Georgia Constitution. Talmadge’s headquarters mailed challenge forms to his supporters across the state and encouraged them to file voter challenges.⁵⁸ This opened the door for many targeted challenges against Black voters, and the Federal Bureau of Investigation (FBI) investigated these claims.⁵⁹ The FBI investigators found that Black voters in various Georgia counties were challenged en masse by Talmadge supporters, who often did not specify exactly which, if any, voting qualification the challenged person had allegedly failed to meet.⁶⁰ Nonetheless, as many as 25,000 Black voters were purged from the rolls across more than thirty counties.⁶¹

Thus, voter challenges have a long history as a tool to suppress Black people’s right to vote. Voter challenge laws, some of which date back to the eighteenth century, have always presented an opportunity for bad-faith actors to question someone’s eligibility to vote and have often had a discriminatory effect. These laws have strayed from the ostensible goal of ensuring that only eligible voters can cast a ballot and instead have been weaponized against voters of color. Today, mass voter challenges continue to create undue burdens for voters who are challenged and have a chilling effect on other Black voters looking to cast their ballot. It is particularly concerning that mass voter challenges have recently surged as backlash to record turnout among Black voters.

ⁱAlso known as the “Civil War Amendments,” the Reconstruction Amendments are the Thirteenth, Fourteenth, and Fifteenth Amendments to the U.S. Constitution. These three amendments were passed following the end of the U.S. Civil War in an effort to establish equal rights for Black people. The Fourteenth and Fifteenth Amendments are most relevant to this Brief, as the former provided citizenship to Black people born in the United States and the latter extended voting rights to Black male citizens.

Part II

MAJOR ISSUES WITH MASS VOTER CHALLENGES TODAY

The Large Volume of Mass Voter Challenges

The volume of mass voter challenges has risen dramatically in recent years. A report from 2012 highlighted egregious examples of challenges from 2000 to 2012 that targeted voters of color, student voters, low-income voters, and voters with disabilities.⁶² It has since become common for hundreds or even thousands of voters to be challenged at once. Since 2020, the number of mass voter challenges being filed has reached unprecedented levels.⁶³ In 2022 alone, groups and individuals challenged 92,000 voters across Georgia.⁶⁴

A Potential Chilling Effect

Mass voter challenges likely have a chilling effect: hearing that some people have had their voting eligibility challenged could dissuade other people from attempting to vote because of their fear that they too will be challenged. Researchers should further study how learning about mass voter challenges impacts voters who are not directly targeted—specifically, whether reading or hearing about mass voter challenges in a potential voter’s state deters them from voting. Mass voter challenges are a voter suppression tool, and existing research suggests that voter suppression tactics such as voter identification laws can have a chilling effect on other voters.⁶⁵

The “Big Lie” and Voter Fraud Myth

The voter fraud myth involves spreading misinformation that election results are inaccurate and that voter fraud is rampant. Over the past five years, this myth has fueled an increase in mass voter challenges. Many of President Donald Trump’s supporters have repeated a discredited voter fraud narrative about the 2020 presidential election: the “Big Lie,” claiming that the election was stolen.⁶⁶ The term “Big Lie” originated from Adolf Hitler, who wielded an antisemitic claim that Jewish people in Europe were the reason Germany lost World War I.⁶⁷ Similarly, the “Big Lie” in the wake of the 2020 U.S. presidential election took a false claim and made it a tool of propaganda, moving a country away from democracy and the truth and toward authoritarianism. Those who believe in the “Big Lie” claim that ineligible voters cast ballots, presumably for Joe Biden, which caused Trump to lose the election.⁶⁸ However, these claims have been repeatedly debunked.⁶⁹ Although Congress certified the Electoral College results and confirmed that Biden won,⁷⁰ some proponents of the “Big Lie” took matters into their own hands and filed voter challenges en masse. Such challenges, which are often filled with inaccuracies and based on insufficient evidence, pose substantial threats to the legitimacy and viability of U.S. democracy.

The recent rise in mass voter challenges is also occurring alongside nationwide efforts to discredit the technology used to maintain voter rolls, including attacks on the Electronic Registration Information Center (ERIC). ERIC is a nonprofit and nonpartisan membership organization that helps states maintain accurate voter registration rolls. ERIC was created shortly after The Pew Charitable Trusts released a 2012 report that concluded that voter registration lists and maintenance processes were outdated.⁷¹ The report recommended a modernized system for voter registration and maintenance that reflected new advancements in technology, and ERIC was launched the same year.⁷²

ERIC uses an intricate system that goes beyond the error-prone technology commonly used to curate names for mass voter challenges.⁷³ Member states routinely submit both voter registration data and data from motor vehicle departments to ERIC. Then, ERIC staff use data-matching software to compare that information across all member states and other sources, such as official death data from the Social Security Administration,⁷⁴ to produce seven “list maintenance” reports.⁷⁵ For example, ERIC licenses data from the U.S. Postal Service to identify voters who have changed their address or moved, and this information makes up ERIC’s National Change of Address (NCOA) report.⁷⁶ The NCOA report is just one part of a larger puzzle that states subscribed to ERIC can use to help maintain their voter rolls. The U.S. Election Assistance Commission, an independent agency of the U.S. government, recommends that when election officials receive NCOA data stating that someone has moved, they should send the person a confirmation of address notice.⁷⁷ Therefore, NCOA data can be a starting point to investigate whether someone is still eligible to vote in a state, but this information should not be the sole deciding factor.

Despite its comprehensiveness, ERIC has faced unwarranted attacks fueled by conspiracy theories. Opponents have attempted to replace ERIC with technology that does not begin to capture the complexity of maintaining voter rolls in a digital age. Many states have recently left ERIC because of unsubstantiated claims of data inaccuracy.⁷⁸ In 2022 and 2023, Alabama,⁷⁹ Louisiana,⁸⁰ Missouri,⁸¹ Florida,⁸² Ohio,⁸³ Iowa,⁸⁴ Texas,⁸⁵ Virginia,⁸⁶ and West Virginia⁸⁷ left ERIC. All of these states, except for Texas and West Virginia, alleged that ERIC had data security issues or was partisan.⁸⁸ ERIC’s leadership denied these allegations in early 2023.⁸⁹

The “Big Lie” and attacks on ERIC have both fed into the growing trend of mass voter challenges. While this Brief focuses on mass voter challenges in Georgia and Florida from 2020 to 2024, it is important to note that mass voter challenges have also been reported in other states, and the phenomenon is not limited to the South.⁹⁰ This Brief focuses on Georgia and Florida because of the volume of voter challenges filed and the attempts to disenfranchise large numbers of eligible Black voters in each state.

Further, analyzing mass voter challenges post-2020 zeroes in on how organizations and individuals have used these challenges as a voter suppression tactic following an election cycle where voters of color took to the ballot box in large numbers. The 2020 presidential election saw high voter registration and turnout rates across the nation, including among voters of color.⁹¹ Two-thirds (66.8%) of all U.S. citizens who were at least eighteen years old cast a ballot, and Asian Americans and Hispanic Americans who were at least eighteen years old saw higher turnout rates than in any presidential election since at least 2008 (fifty-nine percent and fifty-four percent, respectively).⁹² Non-Hispanic Black U.S. citizens who were at least eighteen years old had a higher turnout rate than in 2016 (sixty-three percent vs. sixty percent).⁹³ The increase in mass voter challenges following the 2020 election is likely a response to these high voter turnout rates.

Part III

GEORGIA VOTER CHALLENGES, 2020–2024

Georgia’s Anti-Democracy Laws and Their Connection to Mass Voter Challenges

Two anti-democracy laws recently enacted in Georgia, Senate Bill 189⁹⁴ and Senate Bill 202,⁹⁵ underscore the connection between voter suppression and mass voter challenges. Together, these laws make it easier to file voter challenges by allowing challenges against voters with a “nonresidential” address and allowing people to file an unlimited number of challenges. This expansion of voter challenge laws incorrectly focuses on markers that do not actually make someone ineligible to vote. Instead, the laws place a target on the backs of certain voters, including those who are in college or are unhoused, and make them more susceptible to having their voter eligibility challenged.

The passage of S.B. 189⁹⁶ during the 2023–2024 legislative session amended Chapter 2 of Title 21 of the Official Code of Georgia⁹⁷ to address challenges based on a “nonresidential” address. This law ignores that there are a variety of reasons why someone’s address on their voting file would be “nonresidential” (for example, someone living in a college dormitory or a homeless shelter would have a nonresidential address), and it falsely equates this status with ineligibility to vote in Georgia. The harm of this law was evident within months of its enactment: in the fall of 2024, 689 student voters were challenged in Chatham County, Georgia. The students were either currently or formerly enrolled at Savannah State University,⁹⁸ a historically Black university where most of the student body is Black.⁹⁹

In 2023, a ProPublica article detailed the unique burden placed on unhoused people whose voting eligibility is challenged. The article featured two unhoused people in Forsyth County, Georgia, Joseph Riggs and Barbara Helm. Although their experiences are their own, they speak to larger barriers that many unhoused voters face. Both Riggs and Helm had their voting eligibility challenged and were ultimately removed from the voter rolls ahead of the 2022 election because they did not contest their challenges. Riggs found the process to prove his eligibility to be too laborious, expensive, and dangerous. For example, he would need to take unpaid time off from work and find money for transportation. In addition, he did not want to place himself in danger, as there were reports of arrests being made due to suspected voter fraud. Helm did not see the initial letter notifying her of the challenge in the mail, nor did she receive another letter alerting her of her removal from the voter rolls. The reporters found that Forsyth County was the most aggressive of thirty Georgia counties in approving voter challenges, even though voting rights lawyers warned that the challenges may violate the NVRA.¹⁰⁰ The NVRA set specific limits on how and when voters can be removed from the voter rolls, such as if a voter is confirmed to have died or if the voter confirms in writing that they changed residences.¹⁰¹

Although it is difficult to ascertain the exact number of unhoused voters, the instability of homelessness likely deters many unhoused people from voting. In a 2012 report, the National Coalition for the Homeless estimated that around ten percent of unhoused people vote in elections each year,¹⁰² far less than the estimated fifty-four percent of the total voting-age population that voted in 2012.¹⁰³ In a 2024 article in The Nation, advocates for unhoused voters said a major barrier is misinformation, including the incorrect belief that being unhoused automatically means a person does not have the right to vote.¹⁰⁴ Compounding these issues, a provision of S.B. 189 that prohibits unhoused voters from registering to vote anywhere other than their county registrar’s office went into effect in January 2025.¹⁰⁵ When unhoused people must face the chaos of mass voter challenges on top of these other obstacles, they may be further deterred from registering and voting.

Meanwhile, S.B. 202 allows any eligible voter in Georgia to file an unlimited number of challenges against others in their county.¹⁰⁶ This can encourage baseless mass voter challenges, which have a chilling effect on other voters while also worsening the burdens on the people whose eligibility is challenged and the election officials who must investigate the challenges.

Relying on Faulty Technology

Some individuals who filed mass voter challenges in Georgia between 2020 and 2024 relied on new, unreliable software that is plagued by data errors and limitations. EagleAI and similar tools scrape the internet for pieces of information that can be connected to someone’s voter file, but EagleAI does not have the capacity to verify the information that is scraped. This can easily lead to false matches and incorrect information.¹⁰⁷ Accepting the data from this faulty technology as evidence that someone is ineligible to vote would be a mistake and an affront to democracy. However, in one example, David Sumrall, the head of the Republican Party in Bibb County, Georgia, used EagleAI to generate a list of names and then submitted the challenges to the Bibb County Board of Elections. Sumrall singlehandedly challenged nearly 800 voters, which is around one percent of the county’s total voting population.¹⁰⁸

Various investigations from sources such as Wired¹⁰⁹ and the Brennan Center for Justice¹¹⁰ have found that alternatives to ERIC, including EagleAI, do not have the same capability to cross-check information with other up-to-date databases. Submitting this unreliable information to an election office as the basis of a voter challenge can create real complications: challenged voters are forced to prove their eligibility, and election officials must turn their attention to verifying data that may have come from inaccurate or outdated sources (as discussed further below). When a private citizen uses information that is not proven to be accurate to make a voter challenge, democracy is put in jeopardy.

Placing an Undue Burden on Election Officials

Once someone files a challenge with an election office, election workers must begin the laborious review process. Under Georgia law, the challenged voter has the burden to prove they are eligible to vote after a challenge is filed.¹¹¹ Accordingly, election workers must provide notice to the challenged voter of the claim and hold a hearing. Georgia law does not establish a firm procedure for handling challenges, so the election officials may serve as a resource for challenged voters prior to their court hearing. Attending to mass voter challenges takes away from other critical aspects of an election official’s job, such as maintaining voter rolls and assisting both yet-to-be registered and already-registered voters.

The rise of mass voter challenges has coincided with alarmingly high staff turnover rates at local election offices. A survey from 2023 found that 2020 election denial contributed to high levels of turnover among local election workers.¹¹² Seventy-three percent of officials surveyed said threats against election officials had increased in recent years, and more than half of respondents said they were concerned about bad-faith Freedom of Information Act requests.¹¹³ Furthermore, the survey analysis estimated that if the high turnover rate following the 2020 election cycle held steady, the United States would lose one to two election officials per day by the November 2024 election. Lastly, the survey analysis warned that high turnover could result in more administrative mistakes, which could fuel conspiracy theories and thereby continue the cycle that leads to more resignations.¹¹⁴

Compounding the staffing challenges at local election offices, workers must dedicate considerable time to reviewing mass voter challenges. A 2024 white paper from Protect Democracy argued that mass voter challenges overwhelm election officials by significantly adding to the workload of already under-resourced offices.¹¹⁵ News stories from Georgia confirm this problem: in 2022, Zach Manifold, a Gwinnett County election official, told CNN that five to ten people in the office were working “all day,” six days a week, on challenges that had been filed. Manifold noted that officials had worked to trim a list of thousands of challenges down to 900 that still needed additional research. He expressed concern that dealing with these sizeable challenges would lead to staff burnout and turnover.¹¹⁶ Another 2024 analysis from Protect Democracy found that people filing mass voter challenges often submitted stale data, which created redundant work for election officials in multiple states, including Georgia. The researchers found that a series of challenges in Georgia filed in January 2024 relied on voter data that was already seven months old.¹¹⁷ This situation exemplifies how regular citizens sourcing information and submitting it as “evidence” for a challenge does not equate to credible research that pulls from accurate sources and can be corroborated across multiple fronts.

ANALYSIS OF VOTER CHALLENGES IN GEORGIA

LDF purchased Georgia voter files in December 2024 and received a list in early 2025 of voter ID numbers of 2,002 voters who were challenged. LDF Data and Research Analyst Shruti Banerjee analyzed the list and found that Black voters in Georgia were disproportionately challenged: Black people represented thirty-two percent of voting-age citizens in Georgia,¹¹⁸ yet forty-five percent of the challenged voters.

Additionally, almost all of the challenged Black voters (ninety-five percent) were listed as active voters, which means they had some contact with their local election office in the prior five years. This contact could be through voting, requesting an absentee ballot, or signing a petition.¹¹⁹ Less than half (forty-two percent) of the challenged white voters were listed as active voters.

Sixty-two percent of challenges across the state were against people registered to vote in Fulton County, where Atlanta is located. Fulton County is majority Black, with sixty-four percent of its residents identifying as Black and seventeen percent of residents identifying as white. Forty-six percent of Fulton County’s total citizen voting-age population is Black, while forty-three percent is white.

Based on LDF’s analysis, Black Georgians who were citizens of voting age had their voter status challenged in 2024 at about three times the rate of white people, relative to their share of the population. This finding exemplifies how voter challenges are a voter suppression tool that disproportionately targets Black voters.

The full dataset can be found at https://github.com/Thurgood-Marshall-Institute/Georgia-Voter-Challenges.

Part IV

FLORIDA VOTER CHALLENGES, 2020–2024

Florida’s Anti-Democracy Law and Its Connection to Mass Voter Challenges

Similar to Georgia, Florida also recently enacted an anti-democracy law that advances mass voter challenges. Florida Statute 97.022¹²⁰ (formerly Florida Senate Bill 524¹²¹) created the Office of Election Crimes and Security (OECS) and charged it with “conducting preliminary investigations into any irregularities or fraud involving voter registration, voting, candidate or issue petition activities, or any other alleged violations of Florida’s Election Code.”¹²²

The OECS has published yearly reports on its work, which show that the office is largely coming up empty in its efforts to find and arrest those who allegedly committed voter fraud.¹²³ The OECS reported that of the 2,040 total complaints shared with the office in 2022, only twenty-six arrests were made (although charges and conviction status cannot be inferred from this report).¹²⁴ In the next report, the OECS said it received 1,339 complaints in 2023. This report removed “arrested” as a case status code,¹²⁵ but the executive summary touted one felony conviction for voter fraud and at least twenty arrests for election crimes and other violations.¹²⁶ Analysts have generally found that enforcement units that are similar to the OECS disproportionately target voters of color.¹²⁷ This may also prove true in Florida: when the Tampa Bay Times broke the story of arrests in 2022 following OECS investigations, at least thirteen of the nineteen people arrested were Black.¹²⁸ However, further research is needed to evaluate the OECS-specific data.

Additionally, there is genuine concern among organizations and individuals working at the intersection of racial justice and voting rights that people with felony convictions but who have had their voting rights restored will be specifically targeted for suspicion of voter fraud. The creation of the OECS makes Florida a hotspot for this fear, which has been intensified by widespread media coverage of arrests for alleged voter fraud.¹²⁹ Because voter fraud enforcement and mass voter challenges may target those who had their voting rights suspended following a felony conviction and then recently restored, it is necessary to advocate for reforms to felony disenfranchisement policies alongside reforms to curtail mass voter challenges. In an era of mass incarceration, more than four million people nationwide could not vote as of 2022 due to a felony conviction.¹³⁰ However, progress is being made: as explained in a 2023 report from The Sentencing Project, twenty-six states and the District of Columbia have re-enfranchised formerly incarcerated people, and more than two million people across the country have regained their right to vote since 1997.¹³¹ As states continue to pass reforms, it is important to ensure that mass voter challenges do not undermine the recently restored voting rights of formerly incarcerated people.

Relying on Faulty Technology

As in Georgia, individuals and organizations in Florida have used EagleAI and other similar technology to create lists of names for mass voter challenges, despite the limitations and flaws of such technology. In May 2024, Maria Matthews, Director of the Florida Division of Elections, sent an email in which she directed all Florida supervisors of elections to review a list of approximately 10,000 voters compiled by a “concerned citizen” named Dan Heim. Heim’s email stated that based on NCOA data, he believed that the voters had moved away from Florida and registered to vote elsewhere.¹³² In forwarding Heim’s email and encouraging supervisors to use the list to conduct voter roll maintenance, Matthews likely disregarded state and federal law.¹³³ LDF and coalition partners sent a letter to Matthews and Florida Secretary of State Cord Byrd explaining that Florida state law does not allow for the use of non-governmental entities to conduct list maintenance. Therefore, Matthews’s email passing along a list where she confirmed that she did not know when the information was compiled or which sources were used to create it could potentially violate Florida law¹³⁴—specifically, Florida Statute § 98.075¹³⁵ and Florida Statute § 101.111.¹³⁶ Furthermore, a plethora of federal laws, including the VRA and the First, Fourth, and Fifteenth Amendments to the U.S. Constitution, do not allow government officials to burden the right to vote without just cause. As argued by LDF and coalition partners, Matthews’s email may have violated these federal laws because she instructed supervisors of elections to take action that could have burdened the right of every person on the list to vote.¹³⁷

As previously discussed, using NCOA data as the sole evidence to challenge a person’s voter eligibility is insufficient, as there are a number of reasons why individuals would appear in the NCOA registry. Perhaps most concerning, this incident highlights how even state election officials can be influenced to potentially violate state and federal law. Local election officials work tirelessly to maintain voter rolls throughout the year, but expansive voter challenge laws embolden people like Heim to unnecessarily and unhelpfully take matters into their own hands using error-prone technology.

Placing an Undue Burden on Election Officials

Matthews’s May 2024 email illustrates the significant burden placed on election officials when they receive mass voter challenges. Florida law (specifically Florida Statute § 101.111) provides guidance on what election officials must do in response to a voter challenge.¹³⁸ The process is laborious, as election officials must facilitate the review of the voter challenge and serve as a resource for the challenged voter. Notably, the burden of proof is on the challenged voter, not the person filing the challenge, to demonstrate their eligibility to vote.

Challenges in Florida can only be submitted within thirty days of an election,¹³⁹ which is likely a busy time for election offices as staff respond to general questions from voters while simultaneously preparing for early voting and Election Day. Furthermore, as discussed above, Protect Democracy’s analysis of mass voter challenges submitted in 2024 showed that the challenges were disruptive to the electoral process because they often relied on outdated data and flagged voters who were previously removed during proper voter roll maintenance.¹⁴⁰

In recent years, LDF and other civil rights organizations have co-written letters to election officials in Florida to share best practices around reviewing and responding to voter challenges in accordance with state and federal law.¹⁴¹ Ahead of Florida’s 2024 primary and general elections, the OECS sent Florida supervisors of elections information to support the maintenance of voter rolls, which led some supervisors of elections to file challenges.¹⁴² In an August 2024 letter to all supervisors of elections in Florida, LDF and partner organizations noted that in previous election cycles, they found that supervisors of elections had filed challenges that might be in violation of the law.¹⁴³ The letter reiterated that election officials must follow all applicable laws and defend against frivolous mass voter challenges filed by outside individuals and organizations.

Part V

POLICY RECOMMENDATIONS FOR FUTURE ELECTIONS

Because most states allow private individuals to challenge their fellow citizens’ voter registration or eligibility to cast a ballot, it is imperative that states enforce and expand protections to guard against frivolous voter challenges. This is especially important heading into the 2026 midterm elections. Recent election cycles have exhibited a repeated pattern of mass voter challenges being used as a voter suppression tactic, disproportionately impacting Black voters and other voters of color. The voters whose eligibility is challenged are often left confused and dismayed that their right to vote is being questioned. Meanwhile, election officials experience undue burdens because they must investigate frivolous challenges and challenges seeking to circumvent federal and state protections, which can be time-consuming and costly. To ensure that future elections are rid of voter suppression and that voters have the highest confidence in the election process, LDF recommends the following policies, at a minimum:

States should pass State Voting Rights Acts with protections against voter intimidation and voter suppression. Given federal attacks on the right to vote, states should explore expanding voter protections through State Voting Rights Acts. California, Colorado, Connecticut, Maryland, Minnesota, New York, Oregon, Virginia, and Washington have each passed a State Voting Rights Act to proactively protect voters.¹⁴⁴ States can enact protections against voter suppression to combat discriminatory policies or practices, such as tactics that would lead to unlawful and racially discriminatory voter purges based on biased or unreliable challenges. Of the nine states that have adopted a voting rights act, six include a state-level voter suppression cause of action: Colorado,¹⁴⁵ Connecticut,¹⁴⁶ Maryland,¹⁴⁷ Minnesota,¹⁴⁸ New York,¹⁴⁹ and Virginia.¹⁵⁰ Furthermore, states can use civil voter intimidation provisions to protect against conduct by any actor, whether government officials or private citizens, that results in intimidation. So far, New York¹⁵¹ and Connecticut¹⁵² have included voter intimidation provisions in their State Voting Rights Acts. Other states, such as Michigan¹⁵³ and Minnesota,¹⁵⁴ have adopted civil voter intimidation provisions through standalone legislation.
Jurisdictionsⁱⁱ should wholly comply with the NVRA. In the 1980s and 1990s, various voting rights organizations campaigned to pass the NVRA to make the voter registration process more accessible.¹⁵⁵ One section of the NVRA specifically prevents states and localities from purging their voter rolls less than ninety days before a federal election.¹⁵⁶ Thus, under this provision, mass voter challenges are prohibited ninety days before a federal election.¹⁵⁷ Jurisdictions should adhere to this provision when considering challenges.
States should require the people who file voter challenges to carry the burden of proof and provide information about each individual voter they are challenging. As discussed above, states such as Georgia and Florida place the burden of validating or dismissing a voter challenge on election officials and the challenged voter. For example, if a person in Florida is challenged because someone believes that they have a felony conviction and are ineligible to vote, the challenger does not have to submit proof that the person was actually charged with a felony. Instead, election officials must work to investigate the claim, such as by contacting the Florida Department of Corrections or another state department for information about the challenged voter. The challenged voter is also encouraged to provide information to either confirm or deny the claim. All the while, the person who filed the challenge does not have to contend with the considerable time that election officials are spending on the matter or the emotional toll that the challenged voter is likely experiencing. All states should follow the lead of places like Arizona, which requires “clear and convincing evidence” to file a voter challenge.¹⁵⁸
State election officials should not automatically require challenged voters to vote via provisional ballot. An election office issues a provisional ballot to a voter if the person’s voting eligibility cannot be determined at the polling place. However, voter challenges should abide by due process. LDF recommends that voters not automatically be given a provisional ballot simply because someone filed a challenge against them. Provisional ballots are not counted like regular ballots, as they generally are investigated by election officials within a few days of the election.¹⁵⁹ As such, challenged voters should be able to vote with a regular ballot until and unless election officials determine that they are ineligible to vote.

ⁱⁱThe NVRA is only applicable in forty-four states and the District of Columbia. The states that are excluded are: Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin, and Wyoming.

CONCLUSION

U.S. elections from 2020 to 2024 demonstrated how mass voter challenges can be particularly destructive to political participation. Voters who are challenged may be left discouraged and confused about whether they can participate in the voting process.¹⁶⁰ At the same time, election officials are inundated with challenges that they must review on top of other aspects of their job that are necessary for a healthy democracy. All people should be able to visit their local election office and receive help from a worker who is not on the brink of burning out due to reviewing a mountain of voter challenges.

LDF is in constant pursuit of building a thriving, multi-racial, democratic society where eligible voters do not face these unjust barriers. A core pillar of this work is ensuring that all voters can fully participate in elections without the fear or intimidation that have long plagued people of color in the United States. LDF’s Black Voters on the Rise team is leading the fight “to support Black political engagement by advancing Black voters’ rights and the promise of a free and fair democracy throughout the full life cycle of the democratic process.”¹⁶¹ Mass voter challenges threaten the goal of building Black political power and a thriving American democracy.

State officials must not allow the chaos of mass voter challenges to continue to be used as a voter suppression tactic. States should act swiftly to protect voting rights and rein in mass voter challenges, and everyone should be an active participant in democracy by advocating for these necessary reforms.

Endnotes

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Voting Rights Act of 1965, Pub. L. No. 89-110, 79 Stat. 437 (codified as amended at 52 U.S.C. § 10101 et seq.), https://catalog.archives.gov/id/299909.
Id.
Fifteenth Amendment, 15 Stat. 346 (1869), https://catalog.archives.gov/id/299797.
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Brief of Amicus Curiae NAACP Legal Defense & Educational Fund, Inc. in Support of Respondents, Brnovich v. Democratic National Committee, 594 U.S. 647 (Jan. 20, 2021), https://www.supremecourt.gov/DocketPDF/19/19-1257/166773/20210120105614902_Brnovich%20amicus%20FILING.pdf.
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NAACP Legal Def. Fund, Supreme Court Strikes Down Louisiana Map and Destroys Key Voting Rights Act Provision (Apr. 29, 2026), https://www.naacpldf.org/press-release/supreme-court-strikes-down-louisiana-map-and-destroys-key-voting-rights-act-provision/.
Louisiana v. Callais, 608 U.S. ______ (2026), No. 24-109, slip op. (U.S. Apr. 29, 2026), Kagan, J. dissenting at 3, https://www.supremecourt.gov/opinions/25pdf/24-109_21o3.pdf.
Opinion of the Court, Brnovich v. Democratic National Committee, 594 U.S. 647 (Jul. 1, 2021), https://www.supremecourt.gov/opinions/20pdf/19-1257_g204.pdf.
NAACP Legal Def. Fund, Case: Brnovich v. Democratic National Committee (Jan. 21, 2021), https://www.naacpldf.org/case-issue/brnovich-v-dnc/.
Fair Fight, Inc. v. Engelbrecht, No. 2:20-cv-00302-SCJ, Doc. No. 1 (N.D. Ga. Dec. 23, 2020) at 2, https://clearinghouse.net/doc/142033/.
University of Florida Election Lab, National Turnout Rates Graph, https://election.lab.ufl.edu/national-turnout-rates-graph/.
Jacob Fabina, Despite Pandemic Challenges, 2020 Election Had Largest Increase in Voting Between Presidential Elections on Record, United States Census Bureau (Apr. 29, 2021), https://www.census.gov/library/stories/2021/04/record-high-turnout-in-2020-general-election.html.
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Fair Fight, Inc. v. Engelbrecht, No. 2:20-cv-00302-SCJ, Doc. No. 335 (N.D. Ga. Jan. 2, 2024) at 137, https://www.democracydocket.com/wp-content/uploads/2020/12/2024-01-02-Opinion-And-Memorandum-dckt-335_0.pdf.
Id.
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Ga. Gen. Assy., SB 189, Current Version, https://www.legis.ga.gov/legislation/64471; WSBTV.com News Staff, Georgia election law’s provisions on unhoused voters, absentee ballot storage takes effect, WSB-TV2 Atlanta (Jan. 1, 2025), https://www.wsbtv.com/news/local/atlanta/georgia-election-laws-provisions-unhoused-voters-absentee-ballot-storage-takes-effect/EEXBBC2Y6NAXXB3OR6ARFE2PFE/.
Ga. Elec. Integrity Act of 2021, supra note 95; O.C.G.A. § 21-2-229, https://www.wsav.com/wp-content/uploads/sites/75/2024/10/O.C.G.A.-_-21-2-229-1.pdf; O.C.G.A. § 21-2-230, https://law.justia.com/codes/georgia/2010/title-21/chapter-2/article-6/21-2-230; O.C.G.A. § 21-2-232, https://law.justia.com/codes/georgia/2006/21/21-2-232.html.
TargetSmart, ANALYSIS: Data Infrastructure & Inconsistencies Around Mass Voter Challenges, prepared for Fair Fight (Oct. 7, 2024), https://drive.google.com/file/d/1tCpEFdv_ubvqQwBFZF4ECd-guYnov0e_/view.
Grant Blankenship, A data tool being used to challenge voter registrations is raising many concerns, NPR (Jun. 20, 2024), https://www.npr.org/2024/06/04/nx-s1-4991945/voter-registration-mass-challenges-georgia.
Dhruv Mehrotra, Inside the ‘Election Integrity’ App Built to Purge US Voter Rolls, Wired (Nov. 8, 2022), https://www.wired.com/story/true-the-vote-iv3-app-voter-fraud/.
Michael Waldman, Analysis: EagleAI Isn’t So Intelligent, The Brennan Ctr. for Justice (Sep. 8, 2023), https://www.brennancenter.org/our-work/analysis-opinion/eagleai-isnt-so-intelligent; Alice Clapman and Andrew Garber, A New Antidemocracy Tool, The Brennan Ctr. for Justice (Sep. 5, 2023), https://www.brennancenter.org/our-work/analysis-opinion/new-antidemocracy-tool.
O.C.G.A. § 21-2-229, supra note 106.
Slide Presentation, Resource: Local Election Officials Survey – April 2023, The Brennan Ctr. for Justice (Apr. 25, 2023), https://www.brennancenter.org/our-work/research-reports/local-election-officials-survey-april-2023.
Id. at slides 11-13, 15.
Ruby Edlin and Lawrence Norden, Analysis: Poll of Election Officials Shows High Turnover Amid Safety Threats and Political Interference, The Brennan Ctr. for Justice (Apr. 25, 2023), https://www.brennancenter.org/our-work/analysis-opinion/poll-election-officials-shows-high-turnover-amid-safety-threats-and.
Clint Swift, et al., Unraveling the Rise of Mass Voter Challenges, Protect Democracy (Jun. 2024) at 4, https://protectdemocracy.org/wp-content/uploads/2024/06/Mass-Challenges.pdf.
Fredreka Schouten, Conservative activists in Georgia wage campaign to purge voter rolls ahead of November’s election, CNN (updated Sep. 29, 2022), https://www.cnn.com/2022/09/29/politics/georgia-voter-challenges/index.html.
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CS/CS/SB 524: Election Administration, Bill History, Fla. Senate (updated Apr. 26, 2022), https://www.flsenate.gov/Session/Bill/2022/524.
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Patrick Berry and Gabriella Sanchez, Analysis: Florida Changes Law to Boost Unjust ‘Voter Fraud’ Prosecutions, The Brennan Ctr. for Justice (Feb. 23, 2023), https://www.brennancenter.org/our-work/analysis-opinion/florida-changes-law-boost-unjust-voter-fraud-prosecutions.
Fl. Dep’t State, Florida Department of State Office of Election Crimes and Security Report (Jan. 15, 2023) at 6, 7, 10-90, https://files.floridados.gov/media/706232/dos-oecs-report-2022.pdf.
Fl. Dep’t State, Florida Department of State Office of Election Crimes and Security Report to Legislature (Jan. 15, 2024) at 13, https://files.floridados.gov/media/707435/dos-oecs-report-cy2023-final.pdf (compare to Fl. Dep’t State, supra note 124, at 7, where “arrested” is the first category).
Fl. Dep’t State, supra note 125, at 5-6, 12 (compare to Fl. Dep’t State, supra note 124, at 7, where “arrested” is the first category).
Justin Jouvenal, GOP voter-fraud crackdown overwhelmingly targets minorities, Democrats, The Washington Post (Dec. 20, 2023), https://www.washingtonpost.com/dc-md-va/2023/12/20/voter-fraud-prosecutions-2020/.
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Id. at 2.
Fl. Stat. § 98.075 (2025), https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0000-0099/0098/Sections/0098.075.html.
Fl. Stat. § 101.111 (2025), https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&Search_String=&URL=0100-0199/0101/Sections/0101.111.html.
Ashwell, et al., supra note 133, at 3.
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Id.
Protect Democracy, supra note 117.
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A.R.S. § 16-121.01, https://www.azleg.gov/ars/16/00121-01.htm; Alice Clapman, Arizona: Limits on Voter Eligibility Challenges, The Brennan Ctr. for Justice (updated Sep. 23, 2024), https://www.brennancenter.org/our-work/research-reports/arizona-limits-voter-eligibility-challenges.
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See generally Clark, supra note 100.
Amir Badat and Victoria Wenger, Black Voters on the Rise: How LDF’s Holistic Initiative is Building Black Political Power at a Critical Moment for American Democracy, NAACP Legal Def. Fund (Aug. 9, 2024), https://www.naacpldf.org/black-voters-on-the-rise-building-black-political-power/.

A Growing Affront to U.S. Democracy

Jakiyah Bradley

Published August 2026

Introduction

Part I

MASS VOTER CHALLENGES: A NEW CHAPTER IN THE HISTORY OF VOTER SUPPRESSION

How Voter Suppression Harms American Democracy

Historical Voter Suppression Tactics

The Racially Discriminatory Impact of Voter Challenge Laws

Part II

MAJOR ISSUES WITH MASS VOTER CHALLENGES TODAY

The Large Volume of Mass Voter Challenges

A Potential Chilling Effect

The “Big Lie” and Voter Fraud Myth

Part III

GEORGIA VOTER CHALLENGES, 2020–2024

Georgia’s Anti-Democracy Laws and Their Connection to Mass Voter Challenges

Relying on Faulty Technology

Placing an Undue Burden on Election Officials

ANALYSIS OF VOTER CHALLENGES IN GEORGIA

Part IV

FLORIDA VOTER CHALLENGES, 2020–2024

Florida’s Anti-Democracy Law and Its Connection to Mass Voter Challenges

Relying on Faulty Technology

Placing an Undue Burden on Election Officials

Part V

POLICY RECOMMENDATIONS FOR FUTURE ELECTIONS

iiThe NVRA is only applicable in forty-four states and the District of Columbia. The states that are excluded are: Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin, and Wyoming.

CONCLUSION

ⁱⁱThe NVRA is only applicable in forty-four states and the District of Columbia. The states that are excluded are: Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin, and Wyoming.