D.Ariz blocks citizenship requirement citing Anderson v. Celebrezze

On June 13, 2025, U.S. District Judge DCDenise Casper (District of 🏛️Massachusetts) issued a preliminary injunction blocking President Donald J. Trump’s executive order that would have imposed proof-of-citizenship requirements and eliminated mail-ballot grace periods.

The injunction preserves same-day registration and mail-ballot counting procedures because the court found the proposed restrictions likely violated equal protection, due process, and fundamental voting-rights guarantees.

The court applied strict scrutiny—the highest constitutional standard—for evaluating voting restrictions, requiring a compelling state interest and narrowly tailored means.

Federal injunctions remain in effect during appeals unless a higher court issues a stay; the Trump administration appealed to the First Circuit Court of Appeals and sought emergency review by the Supreme Court.

The ruling noted that roughly 13 million eligible U.S. citizens lack readily available citizenship documentation, meaning the proposed requirements could have disenfranchised far more voters than the typical margin of victory in presidential elections.

Because most jurisdictions use the same procedures for federal, state, and local contests, the injunction’s protections extend across all elections administered under those uniform rules.