Constitutional Showdown: Proof of Citizenship to Vote - The Battle 33 Attorneys General Are Fighting

The Virginia Christian Alliance continues our Constitutional Showdown series framed from the Christian Worldview and Constitutional originalism, exposing how modern courts twist the framers’ original intent while equipping believers to defend constitutional truth through faithful citizenship and prayer.

The Next Battlefield in the Citizenship War

Dear Citizen,

If you’ve been following our Constitutional Showdown series on birthright citizenship, you know we’ve been warning about a fundamental question: Who is legitimately an American citizen?

We’ve covered how Trump’s SCOTUS petition challenges 150 years of constitutional distortion, how the Supreme Court weakened judicial power while birthright citizenship hangs in the balance, and how federal courts blocked Trump’s executive order in a constitutional power struggle.

Now the citizenship battle has reached its logical next step: If we can’t agree on who is a citizen, how can we possibly ensure only citizens are voting?

This week, 33 state attorneys general—split precisely down partisan lines—are locked in a fierce battle over whether Americans should be required to provide proof of citizenship to register to vote. The stakes couldn’t be higher, and the constitutional principles at the heart of this fight connect directly to everything we’ve been discussing about birthright citizenship.

I want to commend excellent reporting on this critical issue by Fred Lucas (@FredLucasWH), chief news correspondent for The Daily Signal. His October 22nd article, “State Attorneys General Weigh in on Requiring Proof of Citizenship to Vote,” provides essential documentation of this developing constitutional showdown. Lucas is also the author of The Myth of Voter Suppression, which thoroughly documents how noncitizens and illegal immigrants have voted in past elections. I encourage every reader to follow his work and support The Daily Signal’s investigative journalism.

Let me build upon Lucas’s excellent reporting with deeper constitutional and biblical analysis of why this battle matters—and why Christians must engage.

The Current Battle: What’s Actually Happening

The U.S. Election Assistance Commission—a four-member federal panel—is reviewing a petition from watchdog group America First Legal to require proof of citizenship on federal voter registration forms.

The Division Could Not Be More Clear:

14 Republican Attorneys General (led by Ken Paxton of Texas) support the requirement, arguing:

“Free and fair elections are the cornerstone of our republic”
“Every illegal vote dilutes the voice of law-abiding American citizens”
Current federal voter registration system “leaves our voter rolls vulnerable”
President Trump’s Executive Order 14248 on election integrity is consistent with federal law

19 Democrat Attorneys General (led by Rob Bonta of California) oppose the requirement, claiming:

It violates the National Voter Registration Act’s limits on what’s “necessary”
It creates “substantial burdens on state and local election infrastructure”
It would cause “disenfranchisement of significant numbers of eligible voters”
“Voting by noncitizens is exceedingly rare”

Moreover, the public has spoken loudly. America First Legal reports that approximately 353,000 public comments were officially registered with the government, with the overwhelming majority in favor of requiring proof of citizenship. The comment period closed Monday, October 21, 2025.

Why This Connects to Our Birthright Citizenship Battle

If you’ve been reading our Constitutional Showdown series, you immediately recognize the connection. The birthright citizenship debate and the proof-of-citizenship-to-vote debate are two sides of the same constitutional coin.

The Logical Progression:

First Question: Who is legitimately a U.S. citizen? (Our birthright citizenship posts)
Second Question: How do we verify citizenship before allowing someone to vote? (This post)
Underlying Issue: Does the 14th Amendment’s “subject to the jurisdiction thereof” clause matter?

As we documented in our analysis of Trump’s SCOTUS petition, the framers of the 14th Amendment specifically included the jurisdictional requirement to exclude those who maintained foreign allegiance or violated American sovereignty. If children born to illegal aliens aren’t automatically citizens—as the framers intended—then certainly illegal aliens themselves shouldn’t be voting.

Furthermore, as we explored in our post on judicial overreach, this isn’t just about immigration policy. It’s about who decides who becomes an American—and by extension, who decides who gets to participate in American self-governance.

The Constitutional Framework: Original Intent on Voting Rights

The Constitution and its amendments establish clear principles about voting eligibility that modern activists conveniently ignore.

The 14th Amendment’s Citizenship Requirement:

Section 2 of the 14th Amendment explicitly ties voting rights to citizenship: “when the right to vote at any election… is denied to any of the male inhabitants of such State, being twenty-one years of age, and citizens of the United States…” (emphasis added). The framers clearly understood that voting is a right of citizens, not merely of inhabitants or residents.

The 15th Amendment’s Affirmation:

“The right of citizens of the United States to vote shall not be denied or abridged…” Again, the framers specified citizens, not persons or residents. This distinction matters.

The 19th Amendment’s Consistency:

“The right of citizens of the United States to vote shall not be denied or abridged… on account of sex.” Once more, the Constitution limits voting to citizens.

The 26th Amendment’s Pattern:

“The right of citizens of the United States, who are eighteen years of age or older, to vote shall not be denied…” The constitutional pattern is unmistakable—voting is exclusively for citizens.

The Framers’ Clear Intent:

The Constitution never contemplates non-citizens voting in federal elections. Therefore, requiring proof of citizenship to register to vote doesn’t add a new burden—it merely enforces the existing constitutional requirement. As Lucas documents in The Myth of Voter Suppression, the notion that verification requirements constitute “voter suppression” collapses under scrutiny when we examine what the Constitution actually requires.

The Biblical Foundation: Honest Weights and Just Measures

Scripture provides clear guidance that directly applies to election integrity and citizenship verification.

Proverbs 11:1 – God Hates Dishonest Scales:

“A false balance is an abomination to the LORD, but a just weight is his delight.” When non-citizens cast ballots, they dilute the votes of lawful citizens. This isn’t just unconstitutional—it’s an offense against God’s standard of justice. Every illegal vote is a “false weight” on the scales of democratic representation.

Proverbs 20:23 – The LORD Detests Dishonest Measures:

“Differing weights are an abomination to the LORD, and false scales are not good.” Election fraud—including votes cast by non-citizens—represents the same kind of injustice that prophets condemned in ancient Israel. God demands honest measurement in commerce, and He demands honest counting in civic life.

Leviticus 19:15 – Justice Without Partiality:

“You shall do no injustice in court. You shall not be partial to the poor or defer to the great, but in righteousness shall you judge your neighbor.” When we allow some to vote without proving citizenship while requiring citizens to follow proper procedures, we show partiality. Justice requires equal standards for all.

Acts 17:26 – God Establishes National Boundaries:

“From one man he made all the nations, that they should inhabit the whole earth; and he marked out their appointed times in history and the boundaries of their lands.” God establishes nations with defined boundaries and memberships. Citizenship matters to God because national sovereignty reflects His divine design.

Romans 13:1-4 – Government’s God-Given Authority:

“Let everyone be subject to the governing authorities, for there is no authority except that which God has established.” Government has divine authority to determine who belongs to the political community and who may participate in self-governance. Requiring proof of citizenship honors this God-ordained authority.

1 Peter 2:13-14 – Submit to Human Authority:

“Submit yourselves for the Lord’s sake to every human authority… to governors as sent by him to punish those who do evil and to praise those who do good.” When non-citizens vote illegally, they violate both divine command and human law. Christians must support verification systems that uphold lawful authority.

The Evidence That Democrat AGs Ignore

Fred Lucas’s reporting for The Daily Signal includes crucial evidence that demolishes the claim that “voting by noncitizens is exceedingly rare.” Let me expand on his documentation:

Recent Documented Cases of Noncitizen Voting:

September 2025 – Iowa School Superintendent: Immigration and Customs Enforcement apprehended Ian Andre Roberts, a Guyanese national allegedly living illegally in the United States, working as a school superintendent in Iowa. He was reportedly a registered Democrat voter in Maryland. (Maryland officials claim no record he voted, but his registration alone proves the vulnerability.)

June 2025 – Chinese National Flees: The FBI announced that a Chinese national charged with illegally voting in Michigan in the 2024 election had fled the country. This case demonstrates that noncitizen voting occurs and that enforcement is difficult when violators can simply leave.

March 2025 – Iowa Audit: An Iowa audit found 277 noncitizens were registered to vote in the state, and 35 actually voted in the 2024 election. This represents just one state’s findings—imagine the national scope.

State Voter Roll Cleanups Reveal the Scale:

Virginia: Removed 6,300 noncitizens from voter rolls since 2022
Alabama: Removed 3,251 noncitizens from rolls
Ohio: Removed 597 noncitizens from rolls
Texas: Removed approximately 6,500 noncitizens since 2021, with 1,900 having voting histories
Pennsylvania: Found more than 11,000 noncitizens registered to vote in 2019

These numbers represent only the noncitizens that states discovered and removed. How many remain undetected? How many more would register if we don’t implement verification requirements?

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The Democrat AG Claim Falls Apart:

California AG Rob Bonta claims “voting by noncitizens is exceedingly rare.” However, the documented evidence from multiple states proves this assertion false. Moreover, Bonta’s claim that “our elections are secure” rings hollow when states keep finding thousands of illegally registered noncitizens.

The real question isn’t whether noncitizen voting occurs—the evidence proves it does. The question is whether we will implement reasonable safeguards to prevent it.

Why the National Voter Registration Act Argument Fails

Democrat attorneys general argue that requiring proof of citizenship violates the National Voter Registration Act (NVRA), which limits the federal voter registration form to what is “necessary” for determining voter eligibility.

This Argument Collapses Upon Examination:

First, citizenship IS necessary for eligibility. The Constitution explicitly reserves voting rights for citizens. Therefore, verifying citizenship is inherently necessary for determining eligibility. The Democrat AGs essentially argue that we cannot verify the single most fundamental requirement for voting—an absurd position.

Second, the NVRA cannot override constitutional requirements. Even if the NVRA limited what could be required on federal forms (a disputed interpretation), Congress cannot pass legislation that prevents enforcement of constitutional citizenship requirements. Constitutional text trumps statutory interpretation.

Third, the framers of the NVRA never contemplated mass illegal immigration. When Congress passed the National Voter Registration Act in 1993, illegal immigration hadn’t reached current crisis levels. The framers of that statute operated in a different context where citizenship verification seemed less urgent. Constitutional principles, however, remain constant regardless of changing circumstances.

Fourth, “substantial burdens” claims ignore modern technology. Democrat AGs claim that proof of citizenship requirements create “substantial burdens on state and local election infrastructure.” However, states already verify numerous other requirements for voter registration—age, residency, felony status. Adding citizenship verification doesn’t create new infrastructure challenges; it simply applies existing verification systems to another constitutional requirement.

Fifth, legitimate citizens can easily obtain documentation. Birth certificates, passports, naturalization certificates—these documents already exist for legitimate citizens. The claim that verification would “disenfranchise significant numbers of eligible voters” assumes that large numbers of citizens cannot obtain documents they already possess or can easily request.

The Democrat AG argument essentially claims that enforcing the Constitution’s citizenship requirement is too difficult, too burdensome, and too harmful. This abandons constitutional fidelity in favor of administrative convenience.

The Real Stakes: National Sovereignty and Self-Governance

This battle over proof of citizenship requirements reveals much deeper stakes than voter registration procedures. At issue is whether America remains a sovereign nation that controls its own political membership.

The Sovereignty Principle:

As we documented in our comprehensive analysis of Trump’s constitutional challenge, national sovereignty includes the right to determine who belongs to the political community. If we cannot even verify citizenship before allowing someone to vote, we have functionally abandoned sovereignty.

The Self-Governance Principle:

Democratic self-governance requires that “the people” who govern be actual members of the political community. When non-citizens vote, they participate in self-governance of a nation to which they don’t belong. This violates the foundational principle that legitimate government derives from the consent of the governed—meaning consent of citizens, not merely inhabitants.

The Precedent Principle:

If states cannot require proof of citizenship for voting, what else can they not verify? Can they not verify age? Residency? Felony status? Once we abandon citizenship verification as “too burdensome,” we undermine all election integrity measures.

The Rule of Law Principle:

As we explored in our post on judicial overreach, the battle over birthright citizenship represents a clash between constitutional text and judicial activism. The same dynamic applies here. Democrat AGs ask us to ignore the Constitution’s explicit citizenship requirement because enforcing it might be inconvenient or politically unpopular.

What the Framers Would Think About This Debate

The idea that we’re even debating whether to require proof of citizenship for voting would utterly baffle the founding generation.

The Framers’ Assumptions:

The Constitution’s framers took citizenship verification so seriously that they required the President to be a “natural born Citizen”—the highest citizenship standard. They never imagined that 250 years later, Americans would debate whether to verify citizenship for ordinary voting.

Early American Practice:

In the founding era and throughout the 19th century, voting was limited to citizens, and communities knew their members personally. As America grew, formal verification became necessary. The framers would view modern resistance to citizenship verification as abandoning the most basic requirement for political participation.

The 14th Amendment Context:

As we documented extensively in our birthright citizenship posts, the 14th Amendment’s framers carefully crafted the “subject to the jurisdiction thereof” requirement to exclude those who maintained foreign allegiance. Senator Jacob Howard, who introduced the amendment, explicitly stated that it did not include foreigners with divided loyalty. The framers would be horrified that modern activists claim we cannot even verify citizenship before allowing voting.

Constitutional Common Sense:

The framers operated from constitutional common sense: Of course only citizens should vote. Of course we should verify citizenship. Of course national sovereignty matters. Modern resistance to these principles represents a dramatic departure from founding principles.

Why Democrat Claims About “Disenfranchisement” Ring Hollow

Democrat attorneys general claim that requiring proof of citizenship would cause “disenfranchisement of significant numbers of eligible voters.” This argument fails on multiple levels.

First, you cannot “disenfranchise” someone by requiring them to prove eligibility. Disenfranchisement means denying the vote to someone who is legitimately entitled to it. Requiring documentation doesn’t deny anyone’s right—it verifies that the right exists. Every legitimate citizen can obtain the necessary documents.

Second, the claim assumes citizens cannot obtain documentation. This insults American citizens by suggesting they’re incapable of acquiring birth certificates, passports, or naturalization papers. The vast majority of citizens already possess these documents for other purposes (employment, travel, benefits).

Third, assistance programs already exist. Multiple organizations help citizens obtain necessary documentation. If documentation access is a genuine concern, the solution is to improve assistance programs, not to abandon verification entirely.

Fourth, the claim prioritizes convenience over constitutional integrity. Even if requiring documentation created some inconvenience for some citizens (a debatable premise), constitutional requirements don’t disappear because they’re inconvenient. We require ID for countless activities—boarding planes, buying alcohol, entering government buildings. Voting for leaders who will govern 330 million Americans surely warrants at least equal verification.

Fifth, Fred Lucas has thoroughly documented that voter suppression claims are mythological. His book The Myth of Voter Suppression systematically dismantles the argument that reasonable verification requirements prevent eligible voters from participating. The data shows that states with stronger verification requirements often have higher voter turnout than states with lax standards.

The Spiritual Warfare Dimension

As believers, we must recognize that resistance to basic election integrity measures reflects deeper spiritual dynamics.

The Father of Lies:

Jesus called Satan “the father of lies” (John 8:44). When we allow voting systems that cannot distinguish citizens from non-citizens, we create systems built on lies—lies about who legitimately belongs to the political community, lies about who has authority to govern, lies about accountability and transparency.

Truth and Justice:

Psalm 89:14 declares, “Righteousness and justice are the foundation of your throne; steadfast love and faithfulness go before you.” God’s throne rests on truth and justice. When we build election systems that cannot verify the most basic eligibility requirement, we violate divine standards of justice.

The Integrity Principle:

Proverbs 10:9 teaches, “Whoever walks in integrity walks securely, but he who makes his ways crooked will be found out.” Election systems with integrity require verification. Systems without verification make our ways crooked, inviting fraud and undermining legitimate authority.

Accountability to God:

Government officials take oaths before God to uphold the Constitution. When attorneys general—whether Republican or Democrat—argue positions contrary to constitutional text, they risk breaking sacred oaths. As Christians, we must pray for leaders to choose constitutional fidelity over political convenience.

What Christians Must Do: Immediate Action Steps

The battle over proof of citizenship requirements demands active Christian engagement. This isn’t a time for passivity—it’s a time for faithful citizenship.

1. Contact Your State Attorney General:

Find out where your state’s AG stands on this issue. If they support requiring proof of citizenship, thank them. If they oppose it, respectfully challenge them with constitutional arguments.

Contact Information Template: “As a citizen and voter, I urge you to support requiring proof of citizenship for voter registration. The Constitution explicitly reserves voting for citizens. Verification doesn’t disenfranchise anyone—it ensures election integrity and honors constitutional requirements. Please stand for constitutional fidelity.”

2. Submit Comments to the Election Assistance Commission:

While the comment period officially closed October 21, ongoing public pressure matters. Visit eac.gov to monitor this issue and communicate your support for citizenship verification requirements.

3. Support Organizations Fighting for Election Integrity:

America First Legal (filed the petition)
Public Interest Legal Foundation
Honest Elections Project
Heritage Foundation’s Election Integrity Initiative

4. Educate Your Church and Community:

Share this article and Fred Lucas’s Daily Signal reporting. Many Christians don’t understand the constitutional issues at stake. Host discussions about citizenship, voting rights, and biblical principles of government.

5. Link This Battle to Birthright Citizenship:

Help others see the connection between determining who is a citizen and verifying citizenship for voting. Share our previous Constitutional Showdown posts on birthright citizenship to show the larger pattern.

6. Pray for Constitutional Clarity:

“If any of you lacks wisdom, you should ask God” (James 1:5). Pray that:

The Election Assistance Commission will rule constitutionally
Attorneys general will prioritize constitutional fidelity over political calculations
Courts will uphold citizenship requirements if challenged
The American people will demand election integrity

7. Prepare for Long-Term Engagement:

This battle won’t end quickly. Whether the EAC rules correctly or incorrectly, the fight for constitutional election integrity will continue. Christians must remain engaged through multiple election cycles.

The Broader Pattern: Citizenship Matters

Throughout our Constitutional Showdown series, we’ve documented a consistent pattern of modern courts, activists, and officials abandoning the framers’ careful distinctions about citizenship.

The Pattern Emerges:

Birthright citizenship distortion: Courts ignore “subject to the jurisdiction thereof” to grant automatic citizenship to children of illegal aliens (our SCOTUS battle post)
Judicial power expansion: Courts issue nationwide injunctions to block presidential authority over citizenship determinations (our Supreme Court weakens post)
Executive-judicial clash: The branches battle over who decides citizenship questions (our EO blocked post)
Voting verification resistance: Officials now claim we cannot even verify citizenship before allowing voting (this post)

The Underlying Crisis:

All of these battles stem from the same root problem: Modern America has lost the framers’ understanding that citizenship is a defined legal status with specific requirements. When we treat citizenship as meaningless—automatically granted to anyone born here regardless of parents’ status, impossible to verify for voting purposes—we undermine the constitutional foundation of American government.

The Biblical Parallel:

In Nehemiah 7, after returning from exile, the Israelites carefully verified genealogies to determine who legitimately belonged to the community. Some “searched for their family records, but they could not find them and so were excluded from the priesthood as unclean” (Nehemiah 7:64). This wasn’t cruelty—it was necessary verification to preserve the community’s identity and integrity.

Similarly, requiring proof of citizenship isn’t about excluding people—it’s about honoring the distinction between citizens and non-citizens that the Constitution establishes and that national sovereignty requires.

Conclusion: Where We Stand in This Constitutional Showdown

The battle over requiring proof of citizenship to vote represents the logical next chapter in our Constitutional Showdown series on citizenship and sovereignty.

The Stakes Are Clear:

If 19 Democrat attorneys general succeed in blocking citizenship verification for voting, they will have effectively erased one of the Constitution’s most fundamental requirements. If 14 Republican attorneys general succeed in implementing verification, they will have restored a basic constitutional principle that never should have been abandoned.

The Connection Is Undeniable:

You cannot separate the birthright citizenship debate from the proof-of-citizenship-to-vote debate. Both ask the same question: Does citizenship matter as a defined legal status, or is it merely a word without meaning?

The Biblical Mandate Is Unambiguous:

God demands honest weights, just measures, truth in government, and respect for established authority. Allowing non-citizens to vote violates all of these principles. Christians must stand for election integrity as a matter of biblical faithfulness, not merely political preference.

The Framers’ Intent Is Crystal Clear:

The Constitution explicitly reserves voting for citizens. The framers never contemplated that we would debate whether to verify this fundamental requirement. Requiring proof of citizenship restores original constitutional meaning; opposing such requirements abandons it.

The Evidence Is Overwhelming:

As Fred Lucas documents in his Daily Signal reporting and his book The Myth of Voter Suppression, noncitizen voting occurs, state audits keep finding illegally registered voters, and the claim that verification would disenfranchise eligible voters collapses under scrutiny.

The Path Forward Requires Action:

This constitutional showdown demands that Christians:

Recognize the connection between citizenship determination and voting verification
Support state attorneys general who defend constitutional requirements
Pressure the Election Assistance Commission to rule correctly
Educate fellow believers about what’s truly at stake
Pray for leaders to choose constitutional fidelity over political expediency

The Choice Is Before Us:

America can restore the framers’ understanding that citizenship is a meaningful legal status with defined requirements and that voting is exclusively for citizens. Or America can continue down the path where citizenship becomes meaningless, borders don’t matter, and anyone physically present can participate in self-governance.

As we’ve documented throughout our birthright citizenship posts, the framers never intended the 14th Amendment to grant automatic citizenship to children of illegal aliens. Now we see the next logical consequence: If citizenship doesn’t matter for determining who is born a citizen, why should it matter for determining who can vote?

The answer is simple: Citizenship must matter, because the Constitution says it matters, because God’s design for nations includes defined membership, and because self-governance requires knowing who “the people” actually are.

The battle continues. The question is whether Christians will engage it with the same passion we bring to other moral and constitutional issues. This isn’t about politics—it’s about preserving constitutional government and honoring biblical principles of justice, truth, and lawful authority.

The Virginia Christian Alliance will continue documenting this constitutional showdown as it develops. Stay engaged. Stay informed. Stay faithful.

And most importantly: Verify citizenship before allowing voting, because the Constitution requires it, God’s justice demands it, and America’s survival depends on it.

For Further Reading and Research:

Primary Source – The Daily Signal: Fred Lucas: “State Attorneys General Weigh in on Requiring Proof of Citizenship to Vote” – October 22, 2025

Follow Fred Lucas on Twitter: @FredLucasWH

Book Resource: The Myth of Voter Suppression by Fred Lucas – Essential reading documenting noncitizen voting and dismantling suppression mythology

VCA Constitutional Showdown Series – Previous Birthright Citizenship Posts:

Constitutional Resources:

State AG Letters:

Organizations Fighting for Election Integrity:

America First Legal – Filed the citizenship verification petition
Public Interest Legal Foundation – State voter roll audits
Heritage Foundation – Election Integrity Initiative
Honest Elections Project

Related VCA Articles:

The views and opinions expressed in this article are those of the authors and do not necessarily reflect the views of the Virginia Christian Alliance.

Comment Policy: We welcome thoughtful and respectful dialogue from all viewpoints. Comments must remain civil, relevant, and free of profanity, personal attacks, or mockery of Christian faith. Disagreement is allowed—disrespect is not.

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