Federal Judge Temporarily Blocks Ohio Law Requiring Documentary Proof of Citizenship for Voting

For a state to mandate documentary proof of citizenship at the ballot box, it must demonstrate that its requirement does not violate the equal protection guarantees of the Fourteenth Amendment. As of Wednesday, a federal court determined Ohio’s newest election law fails that test. A federal district judge issued a temporary restraining order blocking the enforcement of House Bill 114, a statute that required naturalized citizens to present naturalization certificates or passports when registering to vote or updating their registration.[1][4]

The ruling suspends a core component of Ohio’s 2026 election integrity overhaul just weeks before the October 5 voter registration deadline. Under the blocked provision, native-born citizens could register using a standard driver’s license or Social Security number, while naturalized citizens faced the additional hurdle of producing specific federal immigration documents to prove their eligibility.[1][2]

In the 34-page order, the Clinton-appointed judge concluded that the law likely violates the Constitution by creating a two-tiered registration system. "The State has failed to articulate a compelling interest that justifies imposing disparate burdens on naturalized citizens," the court wrote, granting the temporary restraining order requested by a coalition of voting rights groups.[3][4]

Ohio Secretary of State Frank LaRose immediately appealed the decision to the U.S. Court of Appeals for the Sixth Circuit. In a filing submitted late Wednesday, the state argued the injunction disrupts election administration and prevents Ohio from ensuring that only eligible citizens participate in the upcoming midterms.[2][5]

"Noncitizen voting is a felony, and we have a statutory obligation to prevent it before it happens," LaRose said in a statement released by his office. The Secretary of State's office reported that an August 2026 audit identified 597 individuals registered to vote who lacked verified citizenship records, out of more than 8.02 million registered voters in the state.[5]

The legal challenge, filed on August 28, consolidates three separate complaints spearheaded by the American Civil Liberties Union of Ohio and several local civic organizations. They presented evidence that obtaining a replacement N-565 naturalization certificate requires a $555 filing fee, and U.S. Citizenship and Immigration Services estimates a processing time of 9 to 12 months, effectively disenfranchising eligible voters who misplace their original documents.[2][4]

The plaintiffs submitted affidavits from 14 naturalized citizens who were turned away at county boards of elections because they did not have their physical naturalization papers on hand, despite providing valid Ohio driver's licenses. The lawsuit argued this requirement placed an unconstitutional financial and administrative tax on a specific class of voters.[2]

The Sixth Circuit is expected to rule on the emergency stay request within days. If the appellate court lifts the pause, county election boards will have to rapidly implement the documentary requirements for the final three weeks of the registration window. If the block holds, Ohio will revert to its previous system, where voters attest to their citizenship under penalty of perjury.[1][2]