Crawford v. Marion County Election Board
Headline: Indiana’s voter ID law is upheld, allowing the state to require government photo ID for in-person voting while keeping provisional ballots and free IDs for some voters.
Holding: The Court affirmed that the record does not justify striking down Indiana’s law in all applications and that the state’s interests in election integrity and fraud prevention outweigh the limited burdens on most in-person voters.
- Allows Indiana to require government photo ID for in-person voting.
- Requires some voters to cast provisional ballots and visit the county clerk to verify.
- Makes facial challenges harder without strong evidence of widespread burdens.
Summary
Background
A Republican-led Indiana legislature passed SEA 483, which requires people who vote in person to show a government-issued photo ID. Political parties, community groups, and individual voters sued, saying the law would keep some eligible voters from casting regular ballots. The lawsuits were consolidated, and after discovery a federal trial judge granted summary judgment for the State, finding little reliable evidence that the new law would actually prevent eligible people from voting.
Reasoning
The Court weighed the burdens on voters against the State’s stated interests. It noted the State’s goals: deterring in-person voter impersonation, modernizing election procedures, addressing inflated voter rolls, and protecting public confidence. The record showed no proven instances of in-person impersonation in Indiana and only limited evidence that many voters lacked qualifying IDs. The majority applied a balancing approach and concluded the statute’s burdens are limited for most voters, that Indiana provides free IDs, and that provisional ballots and narrow exceptions reduce the risk of actual disenfranchisement. The Court therefore rejected a facial challenge that would invalidate the law in all its applications.
Real world impact
The ruling allows Indiana to enforce its photo ID requirement in person elections. Most voters who already have IDs are unaffected, while some elderly, poor, homeless, or religious-objecting voters may face extra steps. Those voters can cast provisional ballots but must follow post‑election verification procedures to have those ballots counted.
Dissents or concurrances
Justices wrote separately: a concurrence argued the burden is minimal and justified; dissents warned the law could deter tens of thousands of vulnerable voters and criticized the immediate implementation without a broad phase‑in or targeted assistance.
Opinions in this case:
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