Federal judge blocks Ohio proof-of-citizenship requirement for BMV voter registration

A federal judge has blocked an Ohio law requiring people registering to vote through the Bureau of Motor Vehicles to provide documentary proof of U.S. citizenship, prompting Secretary of State Frank LaRose to announce an immediate appeal.

U.S. District Judge Solomon Oliver of the Northern District of Ohio ruled that the requirement conflicts with the federal National Voter Registration Act, which governs voter registration through state motor vehicle agencies.

The provision was included in House Bill 54, Ohio’s transportation budget signed into law in March 2025, and took effect three months later.

Oliver found that Ohio’s requirement placed an additional burden on people registering through the BMV because other methods of voter registration rely on an applicant’s signed attestation of citizenship rather than separate documentary proof.

“That proof of citizenship requirement is more than the signed attestation to U.S. citizenship that Ohio’s other voter registration methods accept,” Oliver wrote.

The order places the requirement on hold while the legal challenge continues.

LaRose, a Republican and defendant in the lawsuit, said the ruling would require the BMV to provide voter registration materials to driver’s license applicants even when they cannot verify their citizenship.

“Under this order, the Bureau of Motor Vehicles would be required to offer a voter registration form to a person who’s applying for a driver’s license, even if that person can’t verify that they’re a citizen,” LaRose said in a statement.

“We strongly disagree with that decision, and I’ve asked our legal team to file an immediate appeal,” he added. “I will vigorously defend our legal authority to safeguard our voter rolls and protect the integrity of Ohio’s elections.”

The lawsuit was filed by Red Wine and Blue, a liberal advocacy organization that argued the requirement creates an unnecessary barrier for eligible voters.

Katie Paris, the group’s founder, questioned why voters registering through the BMV should face a documentary requirement that does not apply through other registration methods.

“Why are they requiring more red tape just to register to vote than is required if you register, say, online?” Paris told the Statehouse News Bureau.

The National Voter Registration Act, commonly known as the “motor voter” law, governs voter registration through state motor vehicle agencies.

The case comes as Ohio lawmakers and voters consider several other proposals involving voter identification and election security.

As Ohio.News previously reported, voters will decide Issue 3 in November, a proposed constitutional amendment that would place Ohio’s existing photo identification requirement for in-person voting into the state constitution.

Ohio law has required government-issued photo identification for in-person voting since 2023. Supporters of Issue 3 argue putting that requirement in the constitution would prevent future legislatures from weakening or eliminating it through ordinary legislation.

The General Assembly has also considered additional identification requirements for absentee voting, although Republican Gov. Mike DeWine vetoed House Bill 472 in June. That measure would have required voters to provide photo identification when voting by mail beginning in 2027.

DeWine said the proposal created additional burdens without providing enough added election security, while Republican legislative leaders argued stronger identification requirements would increase confidence in Ohio elections.

The federal court order applies specifically to the proof-of-citizenship requirement for voter registration through the BMV, while the broader legal challenge continues.