WASHINGTON — A federal court today blocked Ohio from enforcing a documentary proof-of-citizenship requirement that has turned away eligible Ohioans trying to register to vote at the Bureau of Motor Vehicles (BMV), ruling that the requirement is preempted by the National Voter Registration Act (NVRA).
Judge Solomon Oliver, Jr. of the U.S. District Court for the Northern District of Ohio granted a preliminary injunction in Red Wine & Blue v. LaRose, a lawsuit brought by Elias Law Group attorneys in August 2025 on behalf of Red Wine & Blue and the Ohio Alliance for Retired Americans. The lawsuit challenges House Bill 54, which requires voter registration applicants to present additional proof of U.S. citizenship when registering to vote at the BMV.
The court held that the Ohio BMV registration process likely violates the NVRA on two separate grounds. First, the state has been offering voter registration only to people who successfully obtain a license, rather than extending the offer to everyone who submits a license application as federal law requires. As the court put it, Ohio “made the voter registration offer contingent on the success of a person’s driver’s license application,” and that “sequencing is not what Congress intended.”
Second, the court found that H.B. 54’s proof-of-citizenship requirement exceeds the federal standard set by the NVRA. Even the state’s own lawyers have conceded that a signed attestation of citizenship is sufficient for election officials to assess eligibility.
Under the injunction, Ohio may not require any driver’s license applicant, whether applying for the first time or renewing, to produce citizenship documents before being offered the chance to register to vote. The order expressly covers applicants who are turned away without a license for lack of paperwork. It does not extend to applicants who indicate on the BMV form that they are not U.S. citizens.
“Congress passed the National Voter Registration Act to reduce barriers for eligible Americans seeking to register to vote. H.B. 54’s burdensome documentary proof-of-citizenship requirement is exactly the type of government-imposed barrier that the NVRA exists to prevent. With the registration deadline just weeks away, eligible Ohioans will now have the opportunity to register to vote at the BMV without having to produce unnecessary paperwork that is not required by federal law. This ruling is a win for Ohio voters, and we look forward to working with Red Wine & Blue and the Ohio Alliance for Retired Americans to permanently block this anti-voter legislation,” said Elias Law Group Partner Ben Stafford.
Ohio’s voter registration deadline for the November 3, 2026 general election is October 5, 2026.
Read the court’s order here.
###