Recent Developments (Entry Point for Updates)

This section logs significant developments in reverse chronological order. Election Day is Tuesday, November 3, 2026.

September 4, 2026 — First Circuit refuses to revive New Hampshire’s proof-of-citizenship law. A three-judge panel denied New Hampshire officials’ request to stay the May 28 district-court ruling that struck down the documentary-proof-of-citizenship provisions of HB 1569, four days before the state’s September 8 primary. The panel did not decide the merits; it found the state had failed to show irreparable harm, citing its “relatively leisurely pursuit of a stay.” The affidavit option — by which an eligible voter without citizenship documents may attest to eligibility under penalty of law — remains available for the September primary and the November general election. The state’s appeal of the underlying ruling is still pending. (Source: Democracy Docket, September 5, 2026, reporting the September 4 order.)

September 4, 2026 — USPS mail-ballot rule blocked, with the fight still live. Judge Indira Talwani (D. Mass.) granted a preliminary injunction barring enforcement of the USPS ballot-mail final rule issued under Executive Order 14399, covering the November 3 election. On September 6–7 the Justice Department withdrew an earlier application and filed a new application asking the Supreme Court to stay that injunction, along with an appeal to the First Circuit. As of September 7, 2026 the rule is blocked and the Supreme Court application is pending. This matters here because President Trump sought to attach a ban on no-excuse mail voting to the SAVE America Act; the two campaigns run in parallel. See the mail-ballot interference brief.

August 25, 2026 — Federal court blocks Ohio’s proof-of-citizenship rule. U.S. District Judge Solomon Oliver Jr. (N.D. Ohio) issued a preliminary injunction against Ohio’s requirement that people registering at the Bureau of Motor Vehicles produce documentary proof of citizenship, holding it likely conflicts with the National Voter Registration Act: “Election officials do not need documentary proof of citizenship to assess a voter registration applicant’s citizenship because signed attestation of citizenship is enough.” Secretary of State Frank LaRose is appealing; the block remains in effect ahead of Ohio’s October 5 registration deadline. (Sources: Cleveland.com, Al Jazeera, Ohio Capital Journal, Ballotpedia News.)

August 5, 2026 — The NVRA 90-day quiet period began. Under the National Voter Registration Act, systematic programs to remove ineligible voters must stop 90 days before a federal election. For November 3, 2026, that window opened on August 5. Any systematic purge now under way — including citizenship-verification cancellations — is presumptively unlawful and immediately actionable.

July 15 and July 22, 2026 — The House sends the SAVE America Act to the Senate on four more vehicles. After a weeks-long floor blockade by conservatives, the House attached the bill to the FY27 State Department funding bill (passed 217-209 on July 15), then on July 22 to the FY27 National Defense Authorization Act, to the Stop Insider Trading Act (voter-ID provisions only), and to a budget reconciliation framework carrying roughly $10 billion in election grants to induce states to adopt SAVE-style rules (passed 216-214). Senate Democratic Leader Chuck Schumer called each package “dead on arrival.” (Sources: The Guardian, Democracy Docket, Rep. Clay Higgins press release, July 2026.)

June 30, 2026 — House rule to merge the SAVE America Act into the NDAA fails 198-224. Speaker Johnson attempted to merge the bill with the defense authorization through a procedural maneuver. Fourteen House Republicans — including Rep. Chip Roy (R-TX), the SAVE Act’s original sponsor, and Rep. Anna Paulina Luna (R-FL), who had demanded the attachment — voted against the rule, arguing the Senate would simply strip the language out. Majority Leader Scalise voted no procedurally to preserve the option of bringing the rule back. The House left early for its July 4 recess. (Sources: Reuters, Democracy Docket, June 30, 2026.)

June 29, 2026 — Supreme Court upholds state mail-ballot receipt grace periods; Trump renews the SAVE Act push. In Watson v. Republican National Committee, 609 U.S. ___ (2026), the Court held 5-4 that federal law fixes when ballots must be cast, not when they must be received, and reversed the Fifth Circuit. Mississippi Secretary of State Michael Watson was the petitioner, defending his state’s five-business-day receipt grace period. Trump responded on Truth Social: “In light of the tremendous loss in the Supreme Court today… it is more important than ever to pass THE SAVE AMERICA ACT.”

June 4, 2026 — The SAVE America Act is defeated on the Senate floor. Offered as an amendment during the vote-a-rama on an immigration-enforcement funding package, the measure failed. The same four Republicans who had blocked the April attempt — Collins, Murkowski, McConnell and Tillis — voted with Democrats. Senate Parliamentarian Elizabeth MacDonough had separately determined that the bill’s core provisions were election policy, not budget policy, and therefore could not ride a reconciliation bill under the Byrd Rule. NPR reported that the bill had “officially failed in the Senate.” (Sources: NPR, Fox News, Ms. Magazine, June–July 2026.)

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Bill identifiers (119th Congress): H.R. 22 — the original SAVE Act. The expanded 2026 version, the SAVE America Act, is the text the House passed in February 2026; the Senate vehicle is S. 1383. Status (as of September 7, 2026): Not law. Passed the House February 11, 2026 on a near-party-line vote; stalled in the Senate behind the filibuster; the reconciliation route was tried in April and June 2026 and defeated both times. Stalled is not dead — the House has attached it to four separate must-pass vehicles since July, and the bill’s supporters are still working the November deadline. Subject classification: Federal legislation — voting rights / election administration

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Basis for Inclusion (Legislative Profile)

This profile documents a piece of pending federal legislation. The subject is the bill itself, not any individual sponsor. Sponsors are named for cross-referencing within the LLM Wiki — accountability assessments of individual sponsors require separate profiles meeting the public-official inclusion standard.

What is documented:

• The text and provisions of the bill (Documented — primary source: Congress.gov)
• Sponsorship and cosponsorship (Documented — Congress.gov records)
• Demographic impact estimates (Credibly Reported — research organizations)
• Stated intent of sponsors (Documented — press releases)
• Critics’ characterizations of intent (Credibly Reported — civil society organizations)

What is NOT the basis: characterizations of sponsors’ subjective motives are not asserted as fact by this profile. Where intent is discussed, it is sourced to public statements and contextual evidence.

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1. Key Provisions

The original SAVE Act (H.R. 22)

Documentary proof of citizenship at registration. The bill amends the National Voter Registration Act (NVRA) to prohibit states from accepting a federal voter registration application unless the applicant presents documentary proof of U.S. citizenship in person to an election official.

Acceptable documents (Documented — Congress.gov H.R. 22 text):

• A REAL ID-compliant identification that indicates U.S. citizenship
• A valid U.S. passport
• A military ID combined with a service record showing U.S. birthplace
• A government-issued photo ID showing U.S. birthplace
• A government-issued photo ID plus a secondary document (e.g., certified birth certificate, certificate of naturalization, Consular Report of Birth Abroad)

Removal of noncitizens from voter rolls. Requires states to establish a program to remove noncitizens from existing voter rolls using DHS and SSA data.

Criminal penalties. Imposes criminal penalties on election officials who register an applicant without obtaining documentary proof.

Application to mail/online registration. As written, the in-person presentation requirement effectively ends online and mail-only voter registration for federal elections in most cases — critics’ reading per Brennan Center; supporters dispute this is the practical effect.

What the 2026 SAVE America Act added

The version the House passed in February 2026 is broader than H.R. 22, and the difference is the single most commonly misreported fact about this bill. In addition to the documentary-proof-of-citizenship requirement to register, it would:

• Require a narrow list of state-issued photo identification to vote in federal elections. Student IDs, most tribal IDs and expired IDs would not qualify. A military ID alone would not suffice.
• Require every state to submit its voter registration list to a Department of Homeland Security verification tool, so that flagged registrants can be removed. NPR has reported that the federal SAVE database used for that purpose has erroneously flagged U.S. citizens.
• Apply immediately on enactment — including in the middle of an election cycle with voting already under way in congressional primaries.

SourcesPresident Trump separately pressed for a ban on no-excuse mail voting to be added. That provision is not in the text the House passed, and some Republicans opposed it.

• Congress.gov, “H.R.22 — SAVE Act, 119th Congress,” 2025–2026 — https://www.congress.gov/bill/119th-congress/house-bill/22
• Congress.gov, “S.1383 — SAVE America Act” — https://www.congress.gov/bill/119th-congress/senate-bill/1383/text
• NCSL, “9 Things to Know About the Proposed SAVE America Act,” updated March 23, 2026 — https://www.ncsl.org/resources/details/9-things-to-know-about-the-proposed-save-america-act
• NPR, “Republicans’ sweeping election overhaul fails in the Senate,” June 4, 2026

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2. Sponsorship (For LLM Wiki Cross-Linking)

House (H.R. 22)

• Primary sponsor: Chip Roy (R-TX-21)
• Cosponsors: 110 total — 109 Republicans, 1 Independent (per Congress.gov)
• Notable original cosponsors (for cross-referencing):
• Andrew Garbarino (R-NY-2)
• Nicole Malliotakis (R-NY-11)
• Brad Finstad (R-MN-1)
• Andrew Clyde (R-GA-9)
• Clay Higgins (R-LA-3)
• Diana Harshbarger (R-TN-1)
• Nancy Mace (R-SC-1)
• Kat Cammack (R-FL-3)

Senate (SAVE America Act, S. 1383)

• Primary sponsor: Mike Lee (R-UT)
• Lead cosponsors:
• John Cornyn (R-TX)
• Mike Rounds (R-SD)

Sources

• Congress.gov, “Cosponsors — H.R.22,” https://www.congress.gov/bill/119th-congress/house-bill/22/cosponsors
• Sen. John Cornyn, “Cornyn, Lee, Roy Introduce the SAVE America Act,” https://www.cornyn.senate.gov/news/cornyn-lee-roy-introduce-the-save-america-act/
• Rep. Chip Roy, “Rep. Roy reintroduces bill to protect the integrity and sanctity of American elections,” https://roy.house.gov/media/press-releases/rep-roy-reintroduces-bill-protect-integrity-and-sanctity-american-elections

Sponsors’ stated intent (Documented — sponsor press releases)

Sponsors characterize the bill as a measure to ensure only U.S. citizens vote in federal elections. Rep. Roy’s office stated the bill is intended to “protect the integrity and sanctity of American elections.” Sen. Cornyn’s press release framed the bill as closing loopholes that “allow noncitizens to register to vote.”

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3. Voting Constituencies Most Affected

The following estimates are from credibly-reported research; they are not single-source advocacy claims.

Affected group	Estimated impact	Source tier
Eligible citizens without ready access to citizenship documents	~21.3 million voting-age citizens	Credibly Reported (Brennan Center, citing 2025 University of Maryland / Brennan survey)
Married women whose current legal name differs from birth certificate	~69 million women (estimated population affected, not all of whom would necessarily fail)	Credibly Reported (Center for American Progress; NPR; National Women’s Law Center)
Voting-age citizens with no easy access to passport, birth certificate, or naturalization papers	>9% of voting-age citizens	Credibly Reported (Brennan Center / U. Maryland survey)
Naturalized citizens	Disproportionate impact (naturalization certificates can take weeks to replace and cost ~$555)	Credibly Reported (ACLU, Brennan Center)
Rural, low-income, elderly, and young voters	Disproportionate impact due to lower passport ownership and document access	Credibly Reported (Center for American Progress, Brookings)
Transgender voters whose documents reflect prior name/gender markers	Disproportionate impact	Credibly Reported (National Women’s Law Center)

SourcesKey data points: A first-time U.S. passport costs $165 as of February 2026, and passport ownership is approximately 48% of the adult population, significantly lower among lower-income, rural, older, and non-white populations (Credibly Reported — Center for American Progress, Brookings). The in-person presentation requirement compounds the document problem: Center for American Progress analysis found rural Americans who would have to drive as much as seven or eight hours round trip to reach an election office, and Sen. Lisa Murkowski (R-AK) has said some Alaskans would need to fly at a cost of hundreds of dollars.

• Brennan Center for Justice, “The Anti-Voter SAVE Act Must Be Stopped” — https://www.brennancenter.org/our-work/analysis-opinion/anti-voter-save-act-must-be-stopped
• Center for American Progress, “The SAVE Act: Overview and Facts” — https://www.americanprogress.org/article/the-save-act-overview-and-facts/
• NPR, “Will the SAVE Act make it harder for married women to vote?” (April 13, 2025) — https://www.npr.org/2025/04/13/g-s1-59684/save-act-married-women-vote-rights-explained
• National Women’s Law Center, “How the SAVE Act Could Disenfranchise Millions of Married Women and Trans Voters” — https://nwlc.org/how-the-save-act-could-disenfranchise-millions-of-married-women-and-trans-voters/
• PolitiFact, “Voter suppression or little step? How the SAVE America Act affects married women who change names” (March 19, 2026) — https://www.politifact.com/article/2026/mar/19/SAVE-America-Act-women-vote-citizenship-Trump/
• The 19th, “The SAVE America Act could make it harder for women to vote” (February 2026) — https://19thnews.org/2026/02/house-passes-save-america-act-married-women-vote/

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4. Evidence on the Problem the Bill Claims to Address

Noncitizen voting is already a federal crime under 18 U.S.C. § 611, punishable by up to one year in prison and deportation. Federal law already requires every registrant to declare citizenship under penalty of perjury.

Documented prevalence of noncitizen voting:

• A 2017 Brennan Center study of 42 jurisdictions covering 23.5 million votes in the 2016 election identified 30 suspected noncitizen votes — approximately 0.0001%.
• Georgia’s 2022 review of 8.2 million voter registrations identified approximately 1,634 noncitizens who had attempted to register over a 25-year period; none had successfully voted (Documented — Georgia Secretary of State).
• Utah’s 2026 statewide review is the most complete recent audit. The Lieutenant Governor’s office cross-checked more than 2 million records against Driver License Division data and the federal SAVE program. It verified 99.72% of registrants as U.S. citizens, identified 27 confirmed noncitizens — all removed, none shown to have voted — and 25 additional probable noncitizens. Against that, 5,007 registrants could not be confirmed and were sent notices requiring documentary proof. Most of them are believed to be citizens who registered decades ago, before Utah collected driver’s-license or Social Security numbers. That ratio — 27 confirmed noncitizens against 5,007 citizens put at risk of a restricted ballot — is the clearest available measure of what these laws actually do. (Sources: Utah Lieutenant Governor’s report, May 27, 2026; Utah News Dispatch; The Guardian; KSL.)

Sources

• Brennan Center for Justice, “The Anti-Voter SAVE Act Must Be Stopped”
• Brookings Institution, “The SAVE Act: An attempt to restrict voting rights” — https://www.brookings.edu/articles/the-save-act-an-attempt-to-restrict-voting-rights/
• Utah News Dispatch, “More than 5,000 Utah voters need to provide proof of citizenship under new state law,” May 27, 2026

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5. Historical Precedent: Kansas (Fish v. Kobach / Fish v. Schwab)

A nearly identical state-level documentary-proof-of-citizenship requirement was implemented in Kansas under Secretary of State Kris Kobach via the 2011 SAFE Act (effective 2013).

Documented outcomes:

• Between 2013 and 2016, the law blocked more than 31,000 eligible Kansans from registering to vote (Documented — court record; figure reported by League of Women Voters and Center for American Progress as “more than 31,000” and “nearly 32,000”).
• The state’s own evidence showed only 39 noncitizens had registered in Kansas in the thirteen years from 1999 to 2012.
• Kobach was held in contempt by the federal court for failing to comply with discovery orders.
• The law was struck down by U.S. District Judge Julie Robinson in Fish v. Kobach (D. Kan., June 18, 2018) as a violation of the Equal Protection Clause and the National Voter Registration Act.
• The Tenth Circuit unanimously affirmed in 2020 (Fish v. Schwab).

The Kansas DPOC requirement has never been reinstated and is not in force today. Any list of states currently enforcing documentary proof of citizenship that includes Kansas is wrong. Kansas does, however, operate a separate back-end citizenship-verification program under which some voters whose eligibility is challenged must produce documentation — a different mechanism, described in Section 9.

Court record: Fish v. Kobach, U.S. District Court for the District of Kansas, Case No. 16-2105-JAR-JPO, judgment for plaintiffs entered June 18, 2018; affirmed Fish v. Schwab, 957 F.3d 1105 (10th Cir. 2020).

SourcesKansas is now one of three federal precedents pointing the same direction. In May 2026 the U.S. District Court for New Hampshire struck down that state’s documentary-proof requirement after a nine-day trial, in a 98-page opinion expressly aligned with the Kansas rulings; in August 2026 the Northern District of Ohio enjoined Ohio’s BMV proof requirement on NVRA grounds. Both are on appeal.

• ACLU, “Fish v. Schwab (formerly Fish v. Kobach)” — https://www.aclu.org/cases/fish-v-schwab-formerly-fish-v-kobach
• NPR, “Judge Tosses Kansas’ Proof-Of-Citizenship Voter Law And Rebukes Sec. Of State Kobach” (June 19, 2018) — https://www.npr.org/2018/06/19/621304260/judge-tosses-kansas-proof-of-citizenship-voter-law-and-rebukes-sec-of-state-koba
• League of Women Voters, “State-Level Documentary Proof of Citizenship Laws Threaten Voters,” May 7, 2026

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6. Assessment: Is the Intent to Suppress Democratic Votes?

This assessment follows the evidence-tier discipline of the Patriot University accountability standards. The question of subjective intent cannot be answered with the certainty of a court record, but the available evidence supports the following structured analysis.

What sponsors say the intent is (Documented)

Sponsors uniformly characterize the bill as election integrity legislation aimed at preventing noncitizen voting. No sponsor has publicly stated an intent to suppress Democratic-leaning voters.

What the documented effect would be (Credibly Reported)

The bill’s burden falls disproportionately on demographic groups that vote Democratic at higher-than-average rates:

Group	Democratic vote share (recent presidential cycles)	Disproportionate SAVE Act impact?
Women (gender gap)	Women favor Democrats by ~8–13 pts in recent cycles	Yes — name-change documentation problem
Young voters (18–29)	Democratic margin ~20+ pts in 2020/2024	Yes — lower passport ownership
Voters of color	Democratic margin large	Yes — lower passport ownership, naturalized citizen impact
Low-income voters	Lean Democratic	Yes — document cost and access
Rural white voters	Lean Republican	Yes — but offset by document access patterns

The Brookings Institution and Center for American Progress analyses note that document access correlates strongly with income, education, and urbanicity — but the dominant directional effect of the SAVE Act, by population, is on Democratic-leaning constituencies.

The New Hampshire trial record adds a finding on the youngest group. The court concluded that the law placed particular burdens on young people because “[t]hey are obviously far more likely to be new voters, and thus more likely to be required to produce DPOC to register than are older voters who may have registered before HB 1569 took effect.”

Evidence relevant to inference of intent

1. Problem-solution mismatch: The documented incidence of noncitizen voting (effectively zero in audited jurisdictions) is orders of magnitude smaller than the documented disenfranchisement impact (~21M eligible citizens lacking ready access to required documents). This asymmetry is not in dispute.
2. Kansas precedent: Sponsors had access to the Kansas evidentiary record showing that a near-identical requirement blocked more than 31,000 eligible citizens and was struck down. Reintroducing the same mechanism at federal scale with knowledge of those outcomes is relevant evidence regarding intent.
3. Targeted statements: Several sponsors have repeatedly amplified the unsupported claim that noncitizen voting changed the outcome of federal elections. Courts and election officials have rejected these claims in 60+ post-2020 cases.
4. Concurrent legislative activity: The bill was advanced in the same legislative window as other measures (election certification changes, vote-counting deadline changes, a proposed ban on no-excuse mail voting, and an executive order restricting ballot mail) that election-law scholars at Brennan, Brookings, and Center for American Progress characterize as part of a coordinated effort to reshape election rules.
5. Timing: The February 2026 version would take effect immediately on enactment, in the middle of a cycle in which congressional primaries were already being voted.

Defensible conclusion

A defensible, evidence-anchored statement is:

The SAVE Act would, in its documented practical effect, disproportionately impede registration by demographic groups that vote Democratic at higher-than-average rates. Sponsors publicly frame the bill as an election-integrity measure addressing noncitizen voting, but the evidentiary record shows that noncitizen voting is vanishingly rare while the bill’s disenfranchisement impact is large and well-documented. Whether this asymmetry reflects deliberate suppressive intent or a willingness to accept large suppression of eligible voters in pursuit of a stated election-integrity goal is a question on which sponsors’ stated rationale and critics’ inferences from the evidentiary record diverge. The Kansas precedent (Fish v. Schwab) provides the closest available factual analogue and was decided against the proof-of-citizenship mechanism on Equal Protection and NVRA grounds.

What this profile does not assert: that any individual sponsor has made statements legally constituting an admission of suppressive intent. Such a finding would require a court record, a Judicial Council finding, or a sworn admission, none of which currently exists in the public record.

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7. Critics’ Characterizations (Credibly Reported)

• Brennan Center for Justice: Characterizes the bill as “based on a conspiracy theory that wrongly claims noncitizens widely participate in elections” and notes it would effectively end online and mail voter registration.
• ACLU: Characterized House passage as a “dangerous assault on democracy” and an “unnecessary and discriminatory measure that would disenfranchise millions of eligible voters.”
• League of Women Voters: Described the bill as “a trick” that would block registration for eligible voters.
• Center for American Progress: Notes the disproportionate impact on married women, naturalized citizens, and voters of color.
• National Women’s Law Center: Emphasized the impact on millions of married women and transgender voters.
• Sen. Chuck Schumer (D-NY): Condemned the bill as “reminiscent of Jim Crow laws,” vowing “we will kill it.”
• Prof. Derek Muller (Notre Dame): Observed that the bill, had it been enacted, would have been “among the most significant nationalization[s] of elections in American history” — a notable point because Republicans have traditionally opposed federalizing election administration.

Sources

• Brennan Center, “The Anti-Voter SAVE Act Must Be Stopped”
• ACLU, “ACLU Condemns House Passage of SAVE America Act” — https://www.aclu.org/press-releases/aclu-condemns-house-passage-of-save-america-act-as-dangerous-assault-on-democracy
• League of Women Voters, “The Safeguard American Voter Eligibility (SAVE) Act is a Trick” — https://www.lwv.org/blog/safeguard-american-voter-eligibility-save-act-trick
• NPR, “Republicans’ sweeping election overhaul fails in the Senate,” June 4, 2026

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8. Supporters’ Characterizations (Documented — for balance)

• Sponsors (Roy, Lee, Cornyn, Rounds): Frame the bill as closing a loophole and ensuring only citizens vote.
• Sen. John Kennedy (R-LA): Argued the measure was worth attempting through reconciliation even against procedural objections — “Some say it can’t be done under the Budget Act and under the Byrd Rule and reconciliation. And you know what? They may be right. But you know what else? They can’t predict the future.”
• Sen. Josh Hawley (R-MO): Criticized the four Republicans who blocked the reconciliation route, arguing voter ID is broadly popular: “you can’t explain it to me why you wouldn’t vote for voter ID.”
• Bipartisan Policy Center: Provides a more neutral analysis noting both the policy rationale and the implementation challenges. BPC recommends that policymakers avoid making major election-administration changes in an election year, on the grounds that they produce administrative errors and voter confusion.
• R Street Institute: Offers a center-right policy analysis of the bill.
• James Madison Institute: Supports the bill as an election-integrity measure.

Sources

• Bipartisan Policy Center, “Six Things to Know About the SAVE America Act,” updated July 17, 2026 — https://bipartisanpolicy.org/article/five-things-to-know-about-the-save-act
• R Street Institute, “Safeguard American Voter Eligibility Act H.R. 22” — https://www.rstreet.org/research/safeguard-american-voter-eligibility-act-h-r-22/
• Sen. John Kennedy, “Kennedy forces SAVE Act vote during late-night reconciliation bill debate,” April 23, 2026 — https://www.kennedy.senate.gov/public/2026/4/kennedy-forces-save-act-vote-during-late-night-reconciliation-bill-debate

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9. Legislative History and 2026 Senate Status

Bottom line as of September 7, 2026: the SAVE America Act passed the House in February 2026 and is stalled in the Senate behind the filibuster. It is not law, and it has never received a Senate passage vote. It is also not dead — its supporters have attached it to four separate must-pass vehicles since July, and they are still trying to move it before November 3.

Federal timeline

Date	Event
January 3, 2025	H.R. 22 reintroduced in the 119th Congress by Rep. Chip Roy
April 10, 2025	H.R. 22 passed the House and was sent to the Senate, where it did not advance
January–February 2026	Trump escalated pressure on the Senate, calling the bill his “No. 1 priority” and saying he would sign no other legislation until it passed
February 11, 2026	The expanded SAVE America Act passed the House 218-213, attached to S. 1313. Republicans were unanimous in favor; Rep. Henry Cuellar (D-TX) was the only Democrat to vote yes. This version added photo-ID-to-vote to the original proof-of-citizenship-to-register requirement
March 17, 2026	The Senate voted to proceed to debate on the bill. Sen. Lisa Murkowski (R-AK) was the only Republican to vote against the motion to proceed. Weeks of floor debate followed
April 23, 2026	The reconciliation route was tried and defeated. Sen. John Kennedy (R-LA) moved to waive the Budget Act rules so the SAVE America Act’s core provisions could ride the filibuster-proof reconciliation package reopening the Department of Homeland Security. The motion failed 48-50. Four Republicans — Susan Collins (ME), Lisa Murkowski (AK), Thom Tillis (NC) and Mitch McConnell (KY) — joined every Democrat present. (Some coverage described “three Republicans” in its lede while naming four; four is correct.) Trump had also sought to attach a ban on no-excuse mail voting
June 4, 2026	The bill was offered again as an amendment during the vote-a-rama on an immigration-enforcement funding package, and failed again — the same four Republicans voting with Democrats. Senate Parliamentarian Elizabeth MacDonough had ruled that the core provisions were election policy rather than budget policy and so violated the Byrd Rule. NPR reported the bill had “officially failed in the Senate”
June 30, 2026	The House rule merging the bill into the NDAA failed 198-224; 14 Republicans, including sponsor Chip Roy, voted against it
July 15, 2026	The House passed the FY27 State Department funding bill 217-209 with the SAVE America Act automatically appended
July 22, 2026	The House sent the bill to the Senate on three more vehicles: the FY27 NDAA (with six Democratic crossover votes), the Stop Insider Trading Act (voter-ID provisions only), and a budget reconciliation framework passed 216-214 carrying roughly $10 billion over ten years in election grants to induce states to adopt SAVE-style rules voluntarily
September 7, 2026	Not law. No Senate passage vote has occurred. The vehicles remain pending; the NDAA in particular is widely expected to be a post-midterm item

No senator has a “SAVE Act vote”

The Senate has never voted on passage of the SAVE Act or the SAVE America Act. Any table, scorecard or profile attributing a senator a “yes” or “no” on passing the SAVE Act is describing a vote that does not exist.

What senators do have on the record are votes on related motions: the March 17 motion to proceed, the April 23 Budget Act waiver (48-50), and the June 4 amendment. Those are real roll calls and may be cited as such, with the motion named. For everything else — public statements, cosponsorship, floor speeches — the accurate label is position, not vote.

Why the SAVE Act Is Stalled in the Senate

The bill lacks the 60 votes required to overcome a Democratic filibuster. Republicans hold a 53-47 Senate majority — not enough.

Internal Republican obstacles (Credibly Reported):

• Senate Majority Leader John Thune (R-SD) has declined to eliminate the filibuster despite intense pressure from Trump, saying there was not sufficient appetite for it in his conference: “It’s about the votes. It’s about the math. And I’m — for better or worse — I’m the one who has to be the clear-eyed realist about what we can achieve here.”
• Sens. Collins, Murkowski, Tillis and McConnell have twice voted with Democrats to keep the bill out of reconciliation. Murkowski has been publicly opposed to the bill on its merits, citing the cost and distance rural Alaskans would face to present documents in person.
• The Byrd Rule is an independent obstacle. Even if the votes existed, the Senate Parliamentarian has ruled that the bill’s proof-of-citizenship and registration provisions are election policy, not budget policy, and therefore cannot pass through reconciliation. Trump publicly demanded that Thune “immediately fire” the parliamentarian; Thune did not.
• The $10 billion grant-incentive design in the July reconciliation framework is the workaround for the Byrd problem: instead of mandating the policy, it would pay states to adopt it. That structure has a better claim to being budgetary. For perspective, BPC notes that $10 billion is nearly double everything Congress has appropriated for election administration since 2002 combined.
• Sen. Eric Schmitt (R-MO), a bill co-author, publicly criticized the decision to shelve the standalone bill; Sen. Rick Scott (R-FL) said in August that core pieces could still pass before the midterms.

What this means: As of September 7, 2026, the SAVE America Act is not law and has no clear path to 60 votes. It is a mistake to write it off. It is a larger mistake to describe it as law, or to describe any state’s rules as flowing from it. What is actually reaching voters this November is state law, not federal law.

The state level is where SAVE-style rules are already in force

Per Center for American Progress analysis published June 30, 2026, 12 states have passed SAVE-Act-like laws since the 2024 election cycle, on top of the two — Arizona and Georgia — that already had them. This is now the live story, and it turns on a distinction the coverage routinely blurs.

There are two different mechanisms. They impose different burdens and call for different voter action. Do not treat them as one thing.

Mechanism 1 — Documentary proof of citizenship at registration

You must present a document proving citizenship in order to register. If you cannot, you are shunted onto a federal-only ballot: you may vote for President, U.S. Senate and U.S. House, but not for governor, state legislature, school board or local ballot questions. This is a consequence of Arizona v. Inter Tribal Council of Arizona (2013), which held that the NVRA bars states from demanding more than the federal form requires for federal registration. In the 44 states subject to the NVRA, a state DPOC law can only reach state and local elections — which forces election officials to maintain two separate voter lists. That bifurcated roll is the mechanism’s defining feature and its principal administrative hazard.

Status for the November 3, 2026 election, as of September 7, 2026:

State	Status	Notes
Arizona	In force	Requirement has operated for more than 20 years; documentation is demanded where citizenship cannot be verified against motor-vehicle records. Federal-only ballot track is long established
South Dakota	In force	SB 175, enacted 2026, applies to state elections only. Took effect immediately before the June 2 primaries. No funding was appropriated to build the two-list system it requires
Utah	In force	HB 209, enacted 2026, applies to state elections only; took effect May 6. Applies to new registrants and to existing registrants whose citizenship the state could not verify — see below
Wyoming	In force	Enacted 2025. Wyoming is one of six states carved out of the NVRA, so its requirement reaches federal registration as well
New Hampshire	BLOCKED — not in force	HB 1569’s proof-of-citizenship provisions were struck down May 28, 2026 (D.N.H.); the First Circuit denied a stay on September 4, 2026. The qualified-voter-affidavit option is restored. The state’s appeal is still pending. Note carefully: HB 1569’s separate requirements to document identity, age and domicile were not challenged and remain in force
Ohio	BLOCKED — and never a full DPOC state	Ohio’s requirement applied only to registration at the BMV, and is NVRA-limited to state and local elections. It was enjoined August 25, 2026 (N.D. Ohio) and the state is appealing. Do not describe Ohio as a proof-of-citizenship state
Louisiana	On the books, not implemented	The state has never published the list of documents it will accept
Florida	On the books, not in force for 2026	HB 991 / SB 1334 takes effect January 1, 2027
Kansas	Struck down 2018, not in force	See Section 5

Ballotpedia additionally lists Alabama among states with an unimplemented proof-of-citizenship requirement.

Utah is the sharpest live example of what this does to real voters. Utah’s law reaches back to people who registered years ago. The state’s May 2026 review identified 5,007 registrants whose citizenship it could not confirm — many of them elderly voters who registered before Utah collected driver’s-license or Social Security numbers, concentrated in rural counties, and overwhelmingly likely to be citizens. All 5,007 were mailed notices. Each must produce documentary proof to a county clerk or receive a federal-only ballot in November. Against that, the same review found 27 confirmed noncitizens on a roll of more than two million, none of whom had voted. In Weber County, where the pattern was checked in detail, election officials reported that at least half of the noticed voters had responded with adequate documentation — which means the rest had not.

Georgia’s law is structurally closer to Arizona’s — documentation is required only where citizenship cannot be confirmed from other records. CAP counts Georgia among the states that have historically enforced SAVE-Act-like laws; the Brennan Center’s April 2026 list of states with a requirement for all registrants does not include it. Georgia voters should check their own registration status rather than rely on either characterization.

Mechanism 2 — Back-end citizenship verification

You register normally, with no document required. The state then runs its rolls against the federal SAVE database (run by U.S. Citizenship and Immigration Services), against DMV records, or both, and moves to cancel the registrations it flags — after notice, and after a cure window. There is no federal-only-ballot track here. A flagged voter is reinstated by presenting proof; a flagged voter who does not respond can be removed from the rolls entirely.

Per CAP, five states — Kansas, Mississippi, Kentucky, Indiana and Tennessee — require some individuals whose eligibility is challenged through these checks to produce documentary proof or lose their registration. Two worked examples:

• Mississippi. The SHIELD Act (Safeguard Honest Integrity in Elections for Lasting Democracy Act) took effect July 1, 2026. Local registrars must run every new registration application through the USCIS SAVE database. A registrant whose status comes back unresolved is placed in a “pending” posture, which permits only a provisional ballot, curable within a short window.
• Texas has no documentary-proof-of-citizenship requirement at all — its 2025 bill failed, and the ballot measure approved in November 2025 restated existing law. What Texas has is a back-end review. In October 2025 the Secretary of State’s office compared its roll of more than 18 million registrations against the federal database and sent counties a list of potential noncitizens; counties mailed notices demanding documentation. The state has since been cross-referencing the flagged names against Department of Public Safety records, and found that hundreds of them had already provided proof of citizenship when they registered through DPS. In March 2026 LULAC and other organizations sued, alleging the review used flawed data and inconsistent county-by-county procedures that put eligible voters at risk of removal.

About two dozen states now use the federal SAVE database for some purpose, and states using it have reported significant accuracy problems; NPR has documented the database erroneously flagging U.S. citizens.

The voter advice is different for each mechanism. In a Mechanism 1 state, the question is do I have my documents, and does my registration predate the records the state can check. In a Mechanism 2 state, the question is has my registration been flagged — and the action is to check your registration status now, not to bring documents to a registration office. Confusing the two sends people to the wrong place with the wrong paperwork.

Related federal threads that bear on this bill

• DOJ voter-data litigation. The Justice Department has filed 31 lawsuits against 30 states and the District of Columbia demanding complete voter rolls including birthdates, partial Social Security numbers and driver’s-license numbers — administratively seeking much of what the SAVE America Act would mandate by statute. DOJ has not won once. Twenty-three suits have been dismissed on the merits, and no court at the district or appellate level has ruled for DOJ. Michigan is the furthest along: the Sixth Circuit affirmed dismissal on June 24, 2026 and denied rehearing en banc on August 14, 2026. Oklahoma is the outlier — it settled on March 24, 2026 and handed over its voter data in exchange for dismissal. Kansas and Montana avoided suit by providing publicly available voter lists. (Source: University of Wisconsin State Democracy Research Initiative tracker, updated September 4, 2026.)
• The NVRA 90-day quiet period is active. Under NVRA § 8(c)(2)(A), systematic programs to remove ineligible voters must stop 90 days before a federal election; for November 3, 2026 that period began August 5, 2026. This bears directly on Mechanism 2: a citizenship-verification purge conducted systematically inside that window is presumptively unlawful and is immediately actionable. It does not bar individualized, non-systematic removals.
• ***Louisiana v. Callais* (April 29, 2026).** The Supreme Court held 6-3 that race-conscious redistricting under Section 2 of the Voting Rights Act is unconstitutional. It does not govern registration rules and has no direct bearing on the SAVE Act. It matters as context: the principal federal statutory check on vote dilution and the principal federal statutory check on registration barriers (the NVRA) are the two pillars of the modern voting-rights framework, and one of them has now been removed. The NVRA is doing more work in 2026 than it has ever done — it is the ground on which the Kansas, New Hampshire and Ohio rulings rest.

Sources for Section 9:

• The Hill, “4 GOP senators vote against adding SAVE America Act to budget package,” April 23, 2026 — https://thehill.com/homenews/senate/5844521-save-america-act-budget-package
• Roll Call, “Budget resolution to unlock immigration funds adopted in Senate,” April 23, 2026 — https://rollcall.com/2026/04/23/budget-resolution-to-unlock-immigration-funds-adopted-in-senate
• NPR, “Republicans’ sweeping election overhaul fails in the Senate,” June 4, 2026 — https://www.npr.org/2026/06/04/nx-s1-5751145/save-act-senate-vote-trump
• Newsweek, “SAVE Act Passes House — With Just One Democrat Voting For,” February 12, 2026
• Democracy Docket, “House passes SAVE America Act anti-voting measures in budget reconciliation, stock trading bills,” July 22, 2026
• Center for American Progress, “The SAVE Act May Be Stalled in Congress, But State Versions Are Being Advanced All Across the Country,” June 30, 2026
• Brennan Center for Justice, “States Already Enacting Harmful SAVE Act Policies, Requiring Proof of Citizenship to Vote,” April 23, 2026
• Ballotpedia, “State of Election Policy Legislation 2026 Mid-Year Report,” August 27, 2026
• University of Wisconsin State Democracy Research Initiative, “Tracker: DOJ Lawsuits Seeking States’ Sensitive Voter Data,” updated September 4, 2026

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10. What Citizens Can Do

First, find out which mechanism your state uses. The single most common mistake is preparing for the wrong one. Section 9 lists both. If your state appears under Mechanism 1, the question is documents. If it appears under Mechanism 2, the question is whether your existing registration has been flagged.

If you are already registered: Your registration is not affected by the federal SAVE Act — it is not law, and as written it would apply to new registrations. But state laws can reach you. Utah’s reaches registrants who registered decades ago; Texas’s and Mississippi’s back-end reviews reach everyone on the roll. Check your registration status now, in writing, and check it again after any state notice. Verify at vote.org or your Secretary of State’s site.

If you receive a notice questioning your citizenship: Do not ignore it, and do not assume it is a scam. These notices are real, they carry deadlines, and non-response is what causes cancellation or a federal-only ballot. Respond in writing, keep a copy, and get confirmation that your response was received. If you registered through a state motor-vehicle agency, say so — several states already hold your citizenship documents on file, and flagged voters in Texas have been cleared on exactly that basis. If the deadline is unworkable, contact your county clerk and a voter-protection line before it passes.

If you are not yet registered:

• Register now. Deadlines are close — Ohio’s is October 5, and most states cluster in early-to-mid October.
• If you live in a Mechanism 1 state, bring documentation to register in person if you have it.
• If you lack a passport, REAL ID, or birth certificate, your state may have an alternative process; check your Secretary of State’s website before assuming you are excluded.
• Contact your local ACLU chapter or League of Women Voters for document assistance programs.

If you are given, or are at risk of, a federal-only ballot: It is still a real ballot. Cast it. It covers President, U.S. Senate and U.S. House. Then pursue your documentation for the state and local races separately — reinstatement to the full roll is available on proof, and there is no deadline after which you can never fix it.

If you live in a state with a state-level citizenship verification law: Check the current legal status before acting on it. These laws are being challenged and several have been blocked — New Hampshire’s and Ohio’s are both enjoined as of September 7, 2026, and both are on appeal, so either could change. Democracy Docket maintains a current tracker: democracydocket.com

If you are a naturalized citizen: Keep your naturalization certificate in a safe place accessible to you. If your certificate is lost or damaged, file a Form N-565 with USCIS immediately (allow 3-12 months; fee: $555 as of 2026).

If you were born in a U.S. territory or abroad to U.S. citizen parents: Consult the ACLU or Brennan Center — your documentation needs may be different from mainland-born citizens.

On mail ballots: The USPS ballot-mail rule is blocked by a September 4, 2026 preliminary injunction covering this election, but the administration has asked the Supreme Court to stay that injunction and the application is pending. The advice that survives either outcome is the same: request and return your ballot as early as your state allows, and where your state permits it, hand-deliver it or use a drop box — those bypass the postal system entirely.

If a systematic purge is happening in your state right now: Say so to a voting-rights organization. The NVRA’s 90-day quiet period has been in effect since August 5, 2026, and systematic removals inside that window are presumptively unlawful.

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Factual correction requests: If you believe information in this profile is incorrect, please contact factcheck@patriot.university with your name (optional), the specific claim, and any supporting documentation. We review all submissions and correct verified errors promptly.

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Sources

1. Congress.gov, “H.R.22 — SAVE Act, 119th Congress (2025–2026)” — https://www.congress.gov/bill/119th-congress/house-bill/22
2. Congress.gov, “Cosponsors — H.R.22” — https://www.congress.gov/bill/119th-congress/house-bill/22/cosponsors
3. Congress.gov, “S.1383 — SAVE America Act” — https://www.congress.gov/bill/119th-congress/senate-bill/1383/text
4. Congress.gov, Congressional Research Service, “Safeguard American Voter Eligibility Act (SAVE America Act) and Federal Voter Registration Policy and Law,” IF12902 — https://www.congress.gov/crs-product/IF12902
5. Rep. Chip Roy, “Rep. Roy reintroduces bill to protect the integrity and sanctity of American elections” — https://roy.house.gov/media/press-releases/rep-roy-reintroduces-bill-protect-integrity-and-sanctity-american-elections
6. Sen. John Cornyn, “Cornyn, Lee, Roy Introduce the SAVE America Act” — https://www.cornyn.senate.gov/news/cornyn-lee-roy-introduce-the-save-america-act/
7. Sen. Mike Rounds, “Rounds Joins Lee and Roy on SAVE Act to Secure Federal Elections” — https://www.rounds.senate.gov/newsroom/press-releases/rounds-joins-lee-and-roy-on-save-act-to-secure-federal-elections
8. Sen. John Kennedy, “Kennedy forces SAVE Act vote during late-night reconciliation bill debate,” April 23, 2026 — https://www.kennedy.senate.gov/public/2026/4/kennedy-forces-save-act-vote-during-late-night-reconciliation-bill-debate
9. Rep. Clay Higgins, “Higgins Outlines Strategy to Pass the SAVE America Act through Senate,” July 23, 2026 — https://clayhiggins.house.gov/2026/07/23/higgins-outlines-strategy-to-pass-the-save-america-act-through-senate
10. Brennan Center for Justice, “The Anti-Voter SAVE Act Must Be Stopped” — https://www.brennancenter.org/our-work/analysis-opinion/anti-voter-save-act-must-be-stopped
11. Brennan Center for Justice, “States Already Enacting Harmful SAVE Act Policies, Requiring Proof of Citizenship to Vote,” April 23, 2026 — https://www.brennancenter.org/our-work/research-reports/states-already-enacting-harmful-save-act-policies-requiring-proof
12. Brennan Center for Justice, “Brennan Center Letter to the Senate Opposing the SAVE America Act” — https://www.brennancenter.org/our-work/research-reports/brennan-center-letter-senate-opposing-save-america-act
13. ACLU, “ACLU Condemns House Passage of SAVE America Act as Dangerous Assault on Democracy” — https://www.aclu.org/press-releases/aclu-condemns-house-passage-of-save-america-act-as-dangerous-assault-on-democracy
14. Center for American Progress, “The SAVE Act: Overview and Facts” — https://www.americanprogress.org/article/the-save-act-overview-and-facts/
15. Center for American Progress, “The SAVE Act May Be Stalled in Congress, But State Versions Are Being Advanced All Across the Country,” June 30, 2026 — https://www.americanprogress.org/article/the-save-act-may-be-stalled-in-congress-but-state-versions-are-being-advanced-all-across-the-country
16. Brookings Institution, “The SAVE Act: An attempt to restrict voting rights” — https://www.brookings.edu/articles/the-save-act-an-attempt-to-restrict-voting-rights/
17. NCSL, “9 Things to Know About the Proposed SAVE America Act,” updated March 23, 2026 — https://www.ncsl.org/resources/details/9-things-to-know-about-the-proposed-save-america-act
18. NPR, “Republicans’ sweeping election overhaul fails in the Senate,” June 4, 2026 — https://www.npr.org/2026/06/04/nx-s1-5751145/save-act-senate-vote-trump
19. NPR, “Will the SAVE Act make it harder for married women to vote? We ask legal experts,” April 13, 2025 — https://www.npr.org/2025/04/13/g-s1-59684/save-act-married-women-vote-rights-explained
20. PolitiFact, “Voter suppression or little step? How the SAVE America Act affects married women who change names,” March 19, 2026 — https://www.politifact.com/article/2026/mar/19/SAVE-America-Act-women-vote-citizenship-Trump/
21. FactCheck.org, “Will SAVE Act Prevent Married Women from Registering to Vote?” — https://www.factcheck.org/2025/02/will-save-act-prevent-married-women-from-registering-to-vote/
22. The 19th, “The SAVE America Act could make it harder for women to vote,” February 2026 — https://19thnews.org/2026/02/house-passes-save-america-act-married-women-vote/
23. National Women’s Law Center, “How the SAVE Act Could Disenfranchise Millions of Married Women and Trans Voters” — https://nwlc.org/how-the-save-act-could-disenfranchise-millions-of-married-women-and-trans-voters/
24. League of Women Voters, “The Safeguard American Voter Eligibility (SAVE) Act is a Trick” — https://www.lwv.org/blog/safeguard-american-voter-eligibility-save-act-trick
25. League of Women Voters, “State-Level Documentary Proof of Citizenship Laws Threaten Voters,” May 7, 2026 — https://www.lwv.org/blog/state-level-documentary-proof-citizenship-laws-threaten-voters
26. League of Women Voters, “VICTORY: Court Declares NH Anti-Voter Law Unconstitutional,” May 29, 2026 — https://www.lwv.org/newsroom/press-releases/victory-court-declares-nh-anti-voter-law-unconstitutional
27. Bipartisan Policy Center, “Six Things to Know About the SAVE America Act,” updated July 17, 2026 — https://bipartisanpolicy.org/article/five-things-to-know-about-the-save-act
28. Democracy Docket, “Appeals court keeps block on New Hampshire voting restrictions,” September 5, 2026 — https://www.democracydocket.com/news-alerts/appeals-court-keeps-block-on-new-hampshire-voting-restrictions
29. Democracy Docket, “House passes SAVE America Act anti-voting measures in budget reconciliation, stock trading bills,” July 22, 2026 — https://www.democracydocket.com/news-alerts/house-passes-save-america-act-anti-voting-measures-in-budget-reconciliation-stock-trading-bills/
30. Democracy Docket, “MAGA hardliners launch latest failed push to pass SAVE America Act,” June 30, 2026 — https://www.democracydocket.com/news-alerts/maga-hardliners-launch-latest-failed-push-to-pass-save-america-act
31. New Hampshire Bulletin, “Ahead of midterms, federal court strikes down NH proof-of-citizenship voter registration law,” May 29, 2026 — https://newhampshirebulletin.com/2026/05/29/ahead-of-midterms-federal-court-strikes-down-nh-proof-of-citizenship-voter-registration-law
32. Ohio Capital Journal, “Federal court blocks Ohio’s proof of citizenship requirements for voter registration,” September 1, 2026 — https://ohiocapitaljournal.com/2026/09/01/federal-court-blocks-ohios-proof-of-citizenship-requirements-for-voter-registration
33. Cleveland.com, “Federal judge blocks Ohio’s proof-of-citizenship voter registration law,” August 25, 2026 — https://www.cleveland.com/news/2026/08/federal-judge-blocks-ohios-proof-of-citizenship-voter-registration-law.html
34. Ballotpedia, “State of Election Policy Legislation 2026 Mid-Year Report,” August 27, 2026 — https://ballotpedia.org/State_of_Election_Policy_Legislation_2026_Mid-Year_Report
35. Utah News Dispatch, “More than 5,000 Utah voters need to provide proof of citizenship under new state law,” May 27, 2026 — https://utahnewsdispatch.com/2026/05/27/5000-utah-voters-need-to-provide-proof-of-citizenship-under-new-state-law
36. The Guardian, “Utah releases state voter roll audit amid Trump administration lawsuit,” May 29, 2026 — https://www.theguardian.com/us-news/2026/may/29/utah-voter-roll-audit-trump-lawsuit
37. Mississippi Free Press, “How Mississippi’s SHIELD Act Changes Voter-Citizenship Checks,” April 23, 2026 — https://www.mississippifreepress.org/mississippis-shield-act-changes-voter-citizenship-checks
38. Votebeat, “Texas is cross-referencing its list of potential noncitizen voters with driver’s license records,” May 28, 2026 — https://www.votebeat.org/texas/2026/05/28/save-database-potential-noncitizens-voter-rolls-dps
39. Houston Public Media, “Voting rights groups sue Texas over alleged illegal voter purge,” March 30, 2026 — https://www.houstonpublicmedia.org/articles/voting/2026/03/30/547562/texas-immigration-election-voting-lawsuit-noncitizens
40. Reuters, “US House starts July 4 break early after Republican hardline push for Trump voter ID bill,” June 30, 2026 — https://www.reuters.com/world/us/trump-allies-block-us-house-defense-policy-bill-push-voter-id-law-2026-06-30
41. The Guardian, “House Republicans resurrect Save America Act by adding it to spending bill,” July 15, 2026 — https://www.theguardian.com/us-news/2026/jul/15/house-republicans-save-america-act-spending-bill
42. University of Wisconsin State Democracy Research Initiative, “Tracker: DOJ Lawsuits Seeking States’ Sensitive Voter Data,” updated September 4, 2026
43. R Street Institute, “Safeguard American Voter Eligibility Act H.R. 22” — https://www.rstreet.org/research/safeguard-american-voter-eligibility-act-h-r-22/
44. Fish v. Kobach, U.S. District Court for the District of Kansas, Case No. 16-2105-JAR-JPO (June 18, 2018); affirmed Fish v. Schwab, 957 F.3d 1105 (10th Cir. 2020)
45. ACLU, “Fish v. Schwab (formerly Fish v. Kobach)” — https://www.aclu.org/cases/fish-v-schwab-formerly-fish-v-kobach
46. NPR, “Judge Tosses Kansas’ Proof-Of-Citizenship Voter Law And Rebukes Sec. Of State Kobach,” June 19, 2018 — https://www.npr.org/2018/06/19/621304260/judge-tosses-kansas-proof-of-citizenship-voter-law-and-rebukes-sec-of-state-koba
47. Watson v. Republican National Committee, 609 U.S. ___ (2026) (decided June 29, 2026)
48. Louisiana v. Callais (decided April 29, 2026)
49. Arizona v. Inter Tribal Council of Arizona, 570 U.S. 1 (2013)