Welcome to the Grant Institute’s Grant Report. This periodic update highlights key developments impacting election administration, including voting litigation, policymaking, and federal activity.
The Ulysses S. Grant Institute (USGI) is a 501(c)(3) organization established alongside Restoring Integrity and Trust in Elections (RITE), dedicated to the study of voting and elections processes. USGI currently has several scholarly projects underway and, as our programming expands, we look forward to providing timely expert analysis and commentary on relevant topics through this update, as well as on our website and social media channels.
We also welcome contributions. If you have news, commentary, or other relevant information to share, please submit to info@grantdemocracy.org or to Janey Whitney, USGI’s Jaquish-Kenninger Fellow, at janeywhitney@grantdemocracy.org for inclusion in the Grant Report. We are happy to promote studies, papers, projects, events, job openings, and other newsworthy items to those interested in voting and election administration.
Justin Riemer, President, USGI
Alaska
Ten individuals born in American Samoa but now living in Whittier, Alaska, have pleaded not guilty to voter misconduct charges after allegedly registering or attempting to vote by falsely claiming U.S. citizenship. American Samoans are classified as U.S. nationals, not U.S. citizens, and therefore cannot vote in most U.S. elections. The case is related to Tupe Smith, who was arrested shortly after his 2023 election to a regional school board and now faces separate charges.
Arizona
Arizona Republicans are threatening to sue over the proposed Election Procedures Manual (EPM), which just concluded a 30-day public comment period, accusing Secretary of State Fontes of overstepping his authority, citing provisions that could allow apparent non-citizens extra time to prove citizenship along with other alleged problems. Others argue that some of the draft’s guidance conflicts directly with Arizona law, and that only formal legislative changes could shift the rules. 2023’s EPM has been heavily litigated, with courts invalidating multiple components and one court ruling that the process of its adoption violated the state’s Administrative Procedures Act (see more below in Court Watch).
Attorney General Kris Mayes issued an opinion declaring that voters affected by a state error of not collecting proof of citizenship, largely affecting those who received their driver’s license before October 1996 and registered to vote after 2004, cannot have their voter registrations downgraded or canceled for not responding to requests for documentation. State Attorney General opinions do not have the force of law.
California
The California Supreme Court rejected a Republican emergency petition aimed at blocking Proposition 50, state Democrats’ plan to redraw congressional maps and potentially flip five GOP-held seats, from appearing on the November 4th ballot. This marks the court’s second dismissal of a legal challenge to halt the measure. There are additional pending legal challenges.
A 62-year-old California woman has been charged with five felony counts after illegally registering her dog to vote and casting mail-in ballots in the dog’s name. Prosecutors say the dog’s ballot was accepted in the 2021 gubernatorial recall election but rejected in the 2022 primary. The case came to light when the woman self-reported in 2024, though investigators also pointed to social media posts where she showed her dog with an “I Voted” sticker and later noted the dog was still receiving ballots even after the dog had died. If convicted, she faces up to six years in prison. Read the RITE Press Release here.
Florida
Florida’s election in 2000, complete with hanging chads, butterfly ballots, and disputed recounts, is highly notable in election administration and election law. Over the following 25 years, the state overhauled its voting systems and streamlined procedures so effectively that it is now heralded as the “gold standard” in elections administration. The James Madison Institute explains how this impressive turnaround has come to define Florida’s reputation in modern election integrity.
Georgia
A Georgia House Blue-Ribbon Study Committee on Election Procedures will review Georgia’s existing election laws, policies, and administrative practices. A recent meeting examined the role of the State Election Board and heard member suggestions for improvements the legislature could enact. The committee will hold its next meeting in Savannah on September 18.
Georgia legislators are weighing whether to roll back the state’s automatic voter registration system after complaints of felon voter registration, duplicate applications, and inflated voter rolls. Georgia’s General Assembly session will begin in January of 2026.
Hawaii
Kauaʻi counted more drop‑box and mail‑in ballots than the county reports having collected in the 2024 general election. Exactly how many more? That’s where the real confusion lies: the state’s chief elections officer says the gap is round 25 ballots; the Hawaiʻi Supreme Court cited a discrepancy of 39 ballots; a state Elections Commission permitted interaction group found a discrepancy of 661; and Kauaʻi County’s initial envelope logs suggested a staggering gap of 3,772 ballots. The investigation draws on public records, court filings, and correspondence, which confirms inconsistencies across the board. The research alludes to possible weak links in the chain-of-custody records from collection through counting.
Maine
A proposed Maine ballot measure would require voter photo ID and modify various absentee voting procedures.
An Annapolis Alderman has proposed the city adopt ranked-choice voting. The legislation currently sits before the city council.
Minnesota
The Minnesota Office of the Secretary of State is proposing amendments to rules governing election administration. The proposed rules modify language related to voter registration; ballot formatting and instructions; absentee ballot administration; ballot safeguard procedures; mail balloting procedures; testing of voting systems; and election official training.
Missouri
The Missouri Association of County Clerks and Election Authorities announced that the DOJ has reached out to at least two county clerks regarding the Dominion Voting Systems used in the 2020 election.
Pennsylvania
In November, Pennsylvania will have retention elections for three Supreme Court justices who must secure a “yes” vote to serve another 10-year term. This election is high-stakes as long-standing controversies over mail-in voting procedures, redistricting, and election logistics have recently made their way there. Historically, only one such justice has ever been ousted, but this year Republicans are campaigning aggressively for “no” votes, citing those rulings in election cases. If any justice fails to retain, the governor and state Senate would appoint a temporary replacement until an election is held in 2027.
Pennsylvania officials used data to uncover alleged double voting: a man who moved to Florida voted in person there and then also submitted a mail ballot in Bucks County in that same November 2020 election. The Electronic Registration Information Center (ERIC), a multistate data-sharing consortium, is the method by which Pennsylvania collected the data and discovered the discrepancy. Prosecutors have filed charges following the discovery.
Texas
The state legislature has enacted H.B. 4 (PlanC2333) which redraws congressional lines effective for the 2026 election. A federal court in El Paso has scheduled a preliminary injunction hearing for Wednesday, October 1, in a case challenging the plan.
Virginia
Albemarle County Police are investigating Lauren Eddy, the former general registrar, over allegations of financial misconduct connected to her position. Eddy resigned on August 12, and the county Electoral Board has begun recruitment efforts to finish out Eddy’s unexpired term.
West Virginia
Ohio County has raised compensation for poll workers by $60, bringing total pay to $300 ($30 for training and $270 for Election Day), replacing the previous $20/$220 split. The raise is a proactive response to a nationwide poll worker shortage. The county needs nearly 300 workers to staff Election Day operations, which does not include early voting.
Arizona
RNC v. Fontes, No. CV2024-050553 (Maricopa Cnty. Superior Ct.). GOP organizations, supported by Restoring Integrity and Trust in Elections PAC, sued over Arizona’s 2023 Election Procedures Manual, alleging substantive and procedural violations of state law. After an initial dismissal, the Court of Appeals ruled on March 6, 2025 that Secretary of State Fontes violated the state APA. The Arizona Supreme Court granted review on August 20. On September 8, both plaintiffs and the Secretary filed their supplemental briefs.
Georgia
VoteAmerica v. Raffensperger, No. 1:21-cv-01390 (N.D. Ga.). Progressive groups challenged Georgia’s S.B. 202, arguing that its restrictions on mailing prefilled or duplicative absentee ballot applications violated the First and Fourteenth Amendments. Republican organizations intervened to defend the law. After a 2024 trial, the court upheld the challenged provisions on September 8, finding no constitutional violation.
Idaho
March For Our Lives Idaho v. McGrane, No. 1:23-cv-00107 (D. Idaho). Plaintiffs challenged Idaho’s prohibition of student ID to verify voter eligibility. The state won at the federal district court and plaintiffs appealed. Oral argument is scheduled in the Ninth Circuit on September 17, 2025.
Illinois
Bost v. Illinois State Board of Elections, No. 1:22-cv-02754 (N.D. Ill.). Rep. Mike Bost and two GOP elector nominees challenged Illinois’s 14-day mail ballot receipt window. After being dismissed on standing grounds in the district court and the Seventh Circuit, they petitioned the U.S. Supreme Court, which granted review on June 2, 2025. Oral argument is set for October 8.
New Hampshire
Robertson v. Scanlan, No. 218-2025-CV-00951 (Rockingham Superior Ct.). On August 19, 2025, Plaintiffs filed this lawsuit challenging SB 87 which requires voters to verify their identity in order to vote by mail, alleging voter burdens under the state constitution. A State Executive Council member is also under investigation for allegedly using her official email to refer would-be plaintiffs to Elias Law Group who is leading the litigation.
North Carolina
North Carolina State Conference of the National Association of the NAACP v. Moore, No. 18CVS009806-910 (Wake Cnty. Superior Court). On September 5, 2025, a trial court panel upheld North Carolina’s Voter ID law. The litigation began in 2018 after the legislature passed legislation to implement a constitutional amendment to require voter ID that voters overwhelmingly approved. In 2022, the North Carolina Supreme Court ruled the law could be nullified on the grounds it was brought forward by legislators who were elected in racially gerrymandered districts.
United States v. North Carolina State Board of Elections, No. 5:25-cv-00283 (E.D.N.C.). On September 9 a federal court approved a legal settlement between the Department of Justice and State Board of Elections, resolving a lawsuit over missing voter ID numbers in the state’s rolls. The agreement affirms the state’s ongoing Registration Repair Project, which aims to collect missing voter ID data (driver license number, or alternatively, last four digits of Social Security Number) in order to comply with the Help America Vote Act. Affected voters must vote provisionally, but their ballots count in federal races unless they are found ineligible for some other reason. For state and local contests, their ballots may not count if they fail to provide a matching ID number.
Ohio
RedWine & Blue v. LaRose, No. 1:25-cv-01760 (N.D. Ohio). On August 22, 2025, Plaintiffs filed this lawsuit challenging HB 54 which requires the state Bureau of Motor Vehicles to confirm individuals’ citizenship status before offering them a voter registration application, alleging violations under the National Voter Registration Act and federal constitution.
Pennsylvania
Rossman v. Schmidt, No. 516 MD 2024 (Pa. Comm. Ct.). A county commissioner, supported by RITE, seeks to enjoin Pennsylvania’s Department of State from enforcing a 2018 Directive instructing county officials to ignore inaccurate driver’s license or social security numbers on voter registration applications and to add these applicants to the voter registration rolls. Oral argument is scheduled October 7, 2025.
Eakin v. Adams County Board of Elections, No.1:22-cv-340-SPB (W.D. Pa.). On August 26, the Third Circuit affirmed a lower court ruling striking down Pennsylvania’s mail ballot dating requirement. The RNC petitioned for a rehearing en banc on September 9.
Baxter v. Philadelphia Board of Elections, No. 1305 C.D. 2024 (Pa. Comm. Ct.). Plaintiffs challenged Pennsylvania’s mail ballot dating requirements. On September 10, 2025, the Pennsylvania Supreme Court held oral argument.
Utah
The state legislature has made an emergency request to the state Supreme Court seeking to stay a state district court judge’s ruling that Utah’s congressional district boundaries were unconstitutional and ordering the state legislature to redistrict in time for the 2026 election.
After a call by President Trump to largely ban mail-in voting nationwide, he specifically criticized Colorado’s mail voting system while announcing the relocation of Space Command HQ from Colorado to Alabama.
America First Legal Foundation filed a petition with the Election Assistance Commission on July 16 requesting changes to EAC regulations and the National Mail Voter Registration Form that would mandate documentary proof of U.S. citizenship to register for federal elections.
A new study tested ways to encourage voters to verify their paper ballots produced by electronic Ballot Marking Devices (BMDs). Using mock elections with 60 undergraduates, researchers altered some printed ballots to see if voters would detect errors. A digital prompt reminding voters to carefully check their ballots and confirm accuracy boosted verification rates significantly, with 88% of participants catching anomalies. The study suggests that on-screen prompts can motivate voters to review both digital and printed ballots.
The Bipartisan Policy Center has issued a report titled “Modernizing List Maintenance.”
The Center for American Women and Politics at Rutgers-New Brunswick recently ran a study that found beginning with the 1980 presidential election, women have consistently turned out to vote at higher rates than men, and their total number of votes has also exceeded that of male voters.
Director, Rutgers Democracy Lab
View Position
Jason Snead, Executive Director for Honest Elections Project Action, provides commentary on recent election law changes regarding foreign influence in elections and a look at recent ranked-choice voting bans across six states. Read here.