Laws Permitting Noncitizens To Vote In The United States
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This article covers noncitizen voting in the United States. It includes background information about the issue, language from federal law and state constitutions, details about the municipalities that allow noncitizen voting, and a list of states where it is prohibited.
According to the Pew Research Center, there were over 25 million people living in the U.S. in 2020 who were not U.S. citizens. This included approximately 12 million permanent residents living in the U.S. with legal permission, as well as 2 million temporary residents visiting the U.S. for a period of time as students, tourists, foreign workers, foreign officials, etc. Pew's figure also includes approximately 11 million immigrants living in the U.S. illegally.[1][2]
In 1996, the U.S. Congress passed a law prohibiting noncitizens from voting in federal elections, including elections for the U.S. House, U.S. Senate, and presidential elections. This law does not apply to elections for state and local offices. Click here to learn more about recent legal challenges involving noncitizen voting[3]
Click a topic below to learn more:
- Background
- Noncitizen voting in the United States
- Federal law on voting and citizenship
- State constitutions on voting and citizenship
- Ballot measures on noncitizen voting
- Noteworthy events related to noncitizen voting
Background[edit]
According to political scientist Ron Hayduk of San Francisco State University, certain noncitizens were permitted to vote in federal, state, and local elections in 33 states between 1776 and 1924. He argued that granting the right to vote to noncitizens was a common incentive among U.S. territories and new states to attract workers and families to work and populate the lands.[4][5]
Hayduk also argued that immigration can lead to anti-immigrant sentiment and restricted voting rights:
| “ | Contrary to the dominant narrative about a consistent expansion of democracy and political participation in the United States, the history of immigrant suffrage provides a more accurate lens to expose a recurring pattern that runs throughout the history of American voting rights: one step forward and two steps back. An influx of newer immigrants at a point in time sparks a wave of nationalism and nativism—often associated with war or political conflict—and a rollback of voting rights.[4][6] | ” |
States began changing their constitutions to prevent noncitizen voting in the early Twentieth Century. Alabama (1901), Colorado (1902), Wisconsin (1908), Oregon (1914), Kansas (1918), Nebraska (1918), South Dakota (1918), Indiana (1921), Texas (1921), Mississippi (1924), Missouri (1924), and Arkansas (1926) all banned noncitizen voting within three decades. By 1931, noncitizen voting had become so rare that political scientist Leon Aylsworth noted, "For the first time in over a hundred years, a national election was held in 1928 in which no alien in any state had the right to cast a vote for a candidate for any office – national, state, or local."[4]
Decades later in 1996, the U.S. Congress passed a federal immigration enforcement bill called the Illegal Immigration Reform and Immigrant Responsibility Act (IIRAIRA). Section 611 of IIRAIRA criminalized noncitizen voting in federal elections, but the law did not explicitly prohibit noncitizens from voting in state or local elections in accordance with state constitutions and local ordinances.[5]
When the IIRIRA took effect on April 1, 1997, Former President Bill Clinton said that the legislation strengthened "the rule of law by cracking down on illegal immigration at the border, in the workplace, and in the criminal justice system — without punishing those living in the United States legally."[5] However, critics of the IIRIRA said that it "eliminate[ed] due process from the overwhelming majority of removal cases and curtailing equitable relief from removal."[5]
According to Policy and Advocacy Manager Arturo Castellanos Canales of the National Immigration Forum, the City of Takoma Park, Maryland, became the first municipality in the country to restore noncitizen voting in local elections in 1992. "From a legal standpoint, Takoma Park argued that Maryland’s constitution expressly delegates municipalities the power to determine suffrage qualifications for municipal elections in their city charters. In addition, from a practical perspective, Takoma Park argued that citizenship was an irrelevant suffrage qualification when voting for local officials because they deal with local responsibilities, such as parks and recreation, arts programs, public transportation, garbage collection, water, and sewage."[5]
Voters in San Francisco passed a charter amendment called Proposition N in 2016, giving noncitizens the right to vote in the city's school board elections. An official statement of support for the measure said, "All parents, regardless of citizenship, will have the opportunity to become an integral part of their child’s education through the voting process. It is estimated that at least 1 out of 3 children in SF public schools has an immigrant parent. Tens of thousands of SF residents would become eligible to vote in School Board elections."[7]
An official statement opposing Proposition N said, "Like a bad penny, this illegal proposal in violation of the California Elections Code has already been twice defeated by increasing majorities of San Francisco electors – but keeps coming back!!!: It was defeated in 2004 and 2010 ... Needless to say, American citizens living abroad are not allowed to take part in foreign nations’ board of education or other elections."[7]
After Tacoma Park and San Francisco, other municipalities allowed noncitizens to vote in their local elections: New York (2021), Montpelier (2021), Winooski (2021), Oakland (2022), Washington, D.C. (2022), Burlington (2023). Opponents of these policies filed lawsuits at both the state and federal levels to stop noncitizens from voting, arguing that their participation diminished the voting power of legal citizens. This litigation had mixed results. New York's noncitizen voting law was overturned in 2022. San Francisco's law was upheld on appeal in 2023.
In 2018, North Dakota became the first of several states to ban noncitizen voting by changing their constitutions. North Dakotans for Citizen Voting, the group that sponsored Measure 2, supported the ballot measure in posts on its website:[8]
| “ | Currently the constitution doesn't state that only U.S. citizens can vote - it says that U.S. citizens are eligible to vote. This measure clarifies it. There have been a few cases around the state where county auditors sought clarification ... Voting is the fundamental and exclusive right of U.S. citizens. We welcome many people who choose to live temporarily or even permanently in North Dakota, or elsewhere in the United States. But if they want to vote in our elections, they should make the decision to become a U.S. citizen and go through that process. This initiative doesn’t deal with immigration or the problem of voter fraud. Our goal is simple and straightforward: make voting the exclusive right of U.S. citizens. People who support voting as the basic, fundamental right of U.S. citizens will support this ballot measure, and those who want non-citizens to vote will oppose it.[9][6] | ” |
Opponents of Measure 2, including Steven Morrison, a law professor at the University of North Dakota, stated that the measure was unnecessary, “Practically speaking, I don’t see how this would change anything. The question is do you have non-residents, non-citizens voting now?”[10]
After North Dakota, other states passed bans on noncitizen voting, including Alabama (2020), Colorado (2022), Arizona (2022), Florida (2022), Louisiana (2023), and Ohio (2023). Voters in four additional states are deciding similar ballot measure bans in 2024: Iowa, Kentucky, Missouri, and South Carolina.
Noncitizen voting in the United States[edit]
The map below indicates which U.S. states allow or prohibit noncitizen voting in elections for state or local offices. It also indicates which states have approved ballot measures related to noncitizen voting and which states will have ballot measures related to noncitizen voting in the 2024 election. States with no impediments to voting in local elections are also indicated on this map.
Details about noncitizen voting in local elections[edit]
As of June 2024, the District of Columbia and municipalities in California, Maryland, and Vermont allowed noncitizens to vote in some or all local elections. Details about each municipality are listed below. Know of a municipality we're missing? Email us.
California[edit]
- Oakland: In 2022, voters in Oakland approved a charter amendment that read, "Shall the measure to amend the City Charter to allow the City Council by adopting an ordinance, to authorize voting by noncitizen residents, who are the parents, legal guardians, or legally recognized caregivers of a child, for the Office of Oakland School Board Director if they are otherwise eligible to vote under state and local law be adopted?" The amendment was approved with 67% support. Click here to learn more. The law took effect in 2023.
- San Francisco: In 2016, voters in San Francisco passed a charter amendment called Proposition N with 54% support. The amendment read, "Shall the City allow a non-citizen resident of San Francisco who is of legal voting age and the parent, legal guardian or legally recognized caregiver of a child living in the San Francisco Unified School District to vote for members of the Board of Education?" The law took effect in 2018. San Francisco Superior Court Judge Richard B. Ulmer, Jr. struck down Proposition N in July 2022, stating that the law violated the state Constitution. Ulmer ruled that "the [California] Constitution ... reserves the right to vote to a United States citizen, contrary to (the) San Francisco ordinance."[11] To read the full ruling, click here. A California Court of Appeal overturned Ulmer's ruling a few months later, arguing that Prop N was in fact permissible under the state constitution and the City Charter. According to the city of San Francisco's website, "On August 8, 2023, a California Court of Appeal upheld San Francisco’s non-citizen voting program. The decision permits non-citizen parents of children residing in San Francisco to continue to vote in San Francisco Board of Education Elections."[12]
District of Columbia[edit]
The District of Columbia Council passed the D.C. Noncitizen Vote Act in October 2022, allowing noncitizens to vote in local elections. Due to the District's non-state status, all of its legislation must be reviewed by Congress prior to adoption. The D.C. Noncitizen Vote Act overcame bipartisan opposition in the U.S. House of Representatives and passed its congressional review in March 2023.[13]
Advocates of the law argued that noncitizens have an interest in schools, public safety and other issues, and should therefore be allowed to weigh in on public policy decisions. Opponents argued that noncitizens do not have a fundamental right to vote or hold public office in the U.S. and that the legislation dilutes the voting power of U.S. citizens.[14]
In March 2023, a group of seven D.C. voters filed a lawsuit in D.C. Superior Court seeking an injunction to prevent the law from being enforced. The case was moved to the U.S. District Court for the District of Columbia.[13][14]
On March 20, 2024 the court dismissed the challenge. In its opinion, the court held that the plaintiffs "votes will not receive less weight or be treated differently than noncitizens’ votes; they are not losing representation in any legislative body; nor have citizens as a group been discriminatorily gerrymandered, ‘packed,’ or ‘cracked’ to divide, concentrate, or devalue their votes."[15]
Maryland[edit]
Maryland's state constitution specifies that "every citizen of the United States, of the age of 18 years or upwards, who is a resident of the State as of the time for the closing of registration next preceding the election, shall be entitled to vote in the ward or election district in which the citizen resides at all elections to be held in this State."[16] The state constitution gives municipalities the authority to allow people outside those qualifications to vote without requiring state approval of such changes.[17]
The following Maryland municipalities allow noncitizens to vote in local elections as of June 2024:
- Barnesville: The Barnesville town charter defines qualified voters as "having resided therein for six months previous to any town election and being eighteen years of age."[18]
- Cheverly: Any person over the age of 18 who has been a resident of Cheverly for at least 30 days at the time of the election and has not been convicted of a crime is eligible to register to vote in town elections.[19]
- Chevy Chase Section 3: The charter of Chevy Chase Section 3 reads, "'Qualified Voter' shall mean any person who is a resident of Chevy Chase Section 3, without regard to citizenship, and is at least eighteen (18) years of age."[20]
- Garrett Park: The Garrett Park town charter reads, "The town manager shall provide for the registration of voters in a flexible and available manner in order to encourage registration and voting, consistent with the policies adopted by ordinance and the rules and procedures specified by the election judges. Qualified persons may register by universal registration with either Montgomery County or the town, or may register only with the town, including residents who are not citizens of the United States, up to and including election day."[21]
- Glen Echo: Glen Echo's town charter says the following: "Any person who is not a United States citizen, and (a) is a resident of the Town of Glen Echo, (b) is a lawful resident of the United States, and (c) except for the United States citizenship requirement, meets the voter qualifications provided in Section 501(a) may register to vote in Town elections."[22]
- Hyattsville: The Hyattsville town website states, "Hyattsville residents who are not U.S. citizens, or do not wish to register with the State, may use the Hyattsville City Voter Registration Form."[23]
- Martin’s Additions: The Martin's Additions town charter says, "'Qualified Voter' is any person who owns property or any resident of Martin's Additions who is eighteen (18) years of age or over."[24]
- Mount Rainier: Mount Rainier's city charter states that any person who has been a city resident for 30 days or more at the time of a local election, is at least 18 years old, has not been convicted of a felony offense or of buying and selling votes, and is not under mental guardianship may register to vote.[25]
- Riverdale Park: Riverdale Park's town charter states, "(a) Every resident of the town who (1) has the Town of Riverdale Park as his or her primary residence, (2) is at least sixteen (16) years of age, (3) has resided within the corporate limits of the town for at least forty-five (45) days immediately preceding any nonrunoff town election, (4) does not claim the right to vote elsewhere in the United States, (5) has not been found by a court to be unable to communicate a desire to vote, and (6) is registered to vote in accordance with the provisions of § 503 of this charter shall be a qualified voter of the Town."[26]
- Somerset: The Somerset town charter says, "Every person who (1) is at least eighteen years of age, (2) has resided within the corporate limits of the town for fourteen days next preceding any election, and (3) is registered in accordance with the provisions of this Charter, shall be a qualified voter of the town. Every qualified voter of the town shall be entitled to vote at any or all town elections."[27]
- Takoma Park: The Takoma Park city website states, "City residents who are not citizens of the United States can register to vote in Takoma Park elections by completing the Takoma Park Voter Registration Application."[28]
Vermont[edit]
The following Vermont municipalities allow noncitizens to vote in local elections as of June 2024:
- Burlington: On March 9, 2023, the city of Burlington approved a charter amendment extending the right to vote to its noncitizen residents. Although Governor Phil Scott vetoed the legislation, both chambers of the state legislature voted to override that veto on June 30. The law took immediate effect.[29][30]
- Montpelier: On June 24, 2021, H177 was enacted into law, approving a Montpelier city charter amendment authorizing legal residents to vote in city elections. Although Governor Phil Scott (R) vetoed the legislation, both chambers of the state legislature voted to override that veto. The law took immediate effect.[29][31]
- Winooski: On June 24, 2021, H 227 was enacted into law, approving a Winooski city charter amendment authorizing legal residents to vote in city and school district elections. Although Governor Phil Scott vetoed the legislation, both chambers of the state legislature voted to override that veto. The law took immediate effect.[29][32]
States where noncitizen voting is prohibited[edit]
As of June 2024, the following seven states included language explicitly prohibiting noncitizen voting in their state constitutions.[33]
States with no impediments to noncitizen voting in local elections[edit]
Joshua A. Douglas, associate professor of law at the University of Kentucky College of Law, published an article in 2017 stating, "Municipalities can expand voting rights in local elections if there are no explicit state constitutional or legislative impediments and so long as local jurisdictions have the power of home rule." Some states, for example, require that changes to local charters get approval from state legislatures, thereby limiting municipal authority over voter eligibility laws, whereas other states do not.[34]
Douglas identified 14 states—including California and Maryland—as posing no clear impediments to municipalities passing their own voter qualification laws. Since publication of the 2017 article, two states which Douglas identified as having no clear impediments to noncitizen voting have passed constitutional amendments clarifying that only U.S. citizens may vote in elections in those states. The remaining 12 states identified by Douglas are:
- Arkansas
- California
- Illinois
- Maryland
- Nevada
- New Jersey
- New Mexico
- Oklahoma
- Rhode Island
- South Dakota
- Washington
- Wisconsin[35]
Federal law on voting and citizenship[edit]
Federal law states that it is unlawful for a noncitizen to vote in federal elections and establishes the punishment of a fine, one year in prison, or both for violation of the law. The Illegal Immigration Reform and Immigrant Responsibility Act of 1996 states the following:
| “ |
(a) It shall be unlawful for any alien to vote in any election held solely or in part for the purpose of electing a candidate for the office of President, Vice President, Presidential elector, Member of the Senate, Member of the House of Representatives, Delegate from the District of Columbia, or Resident Commissioner, unless—
(b) Any person who violates this section shall be fined under this title, imprisoned not more than one year, or both.[6] |
” |
The law includes the following exceptions:
| “ |
(c) Subsection (a) does not apply to an alien if—
|
” |
Federal law also states that noncitizens who violate the law are inadmissible (ineligible to receive visas and ineligible to be admitted to the U.S.) and deportable.[36][37]
State constitutions on voting and citizenship[edit]
All state constitutions mention United States citizenship when discussing who can vote in that state's elections. In 43 states, constitutional language discussing citizenship says who can vote (e.g. "every citizen" or "all citizens"), but does not state that noncitizens cannot vote. In seven states (Alabama, Arizona, Colorado, Florida, Louisiana, North Dakota, and Ohio), their constitutions allow citizens, but not noncitizens, the right to vote.
The following table lists what each state's constitution says regarding citizenship and the right to vote. Click the arrow to browse pages in the chart or search for a state within the chart.
Ballot measures on noncitizen voting[edit]
Since 2018, voters have decided on six ballot measures related to adding language about citizenship requirements for voting. Voters approved all six measures with at least 62.9% of the vote. In 2024, eight states are voting on ballot measures addressing citizenship requirements for voting.
Partisanship of legislative votes on referred measures[edit]
The following table shows the percentage of Democratic and Republican legislators that supported referring constitutional amendments to the state's ballot requiring citizenship to vote. The average percent of Republican support was 100% while the average percent of Democratic support was 45.6%.
In Alabama and Iowa, legislators passed the referrals with unanimous support from both parties.
Noteworthy events[edit]
Noncitizen voting in San Francisco upheld by California Court of Appeal (2023)[edit]
According to the city of San Francisco's website, non-citizen parents of children residing in San Francisco are permitted to vote in San Francisco Board of Education elections. Noncitizens are not permitted to vote in other local, state, or federal elections.
In 2016, voters in San Francisco passed a charter amendment called Proposition N with 54% support. The amendment read, "Shall the City allow a non-citizen resident of San Francisco who is of legal voting age and the parent, legal guardian or legally recognized caregiver of a child living in the San Francisco Unified School District to vote for members of the Board of Education?" The law took effect in 2018. San Francisco Superior Court Judge Richard B. Ulmer, Jr. struck down Proposition N in July 2022, stating that the law violated the state Constitution. Ulmer ruled that "the [California] Constitution ... reserves the right to vote to a United States citizen, contrary to (the) San Francisco ordinance."[38] To read the full ruling, click here.
A California Court of Appeal overturned Ulmer's ruling a few months later, arguing that Prop N was in fact permissible under the state constitution and the City Charter. According to the city of San Francisco's website, "On August 8, 2023, a California Court of Appeal upheld San Francisco’s non-citizen voting program. The decision permits non-citizen parents of children residing in San Francisco to continue to vote in San Francisco Board of Education Elections."[39]
Noncitizen voting declared unconstitutional in New York (2022)[edit]
On December 9, 2021, the New York City Council approved Int. 1867-2020, which extended the right to vote in municipal elections to lawful permanent residents and other non-citizens authorized to work in the United States. The council voted 33-14 in favor of the legislation, making New York City the largest city in the nation at the time to authorize voting by non-citizens.[40]
Mayor Eric Adams (D) allowed the legislation to become law without his signature on January 9, 2022, saying, “I believe that New Yorkers should have a say in their government, which is why I have and will continue to support this important legislation. ... I look forward to bringing millions more into the democratic process."[41][42]
A group of Republican voters and officials representing the New York Republican State Committee and Republican National Committee, as well as a Democratic city council member, filed a lawsuit on January 10, 2023, challenging the new law. The plaintiffs alleged that allowing over 800,000 eligible noncitizens to vote in municipal elections when New York City has approximately five million registered voters would dilute the power of the votes of legitimate U.S. citizens.[43]
On June 27, 2022, the New York State Supreme Court for Staten Island overturned the law, ruling that it violated the state's constitution. According to Judge Ralph Porzio, “by not expressly including non-citizens in the New York State Constitution, it was the intent of the framers for non-citizens to be omitted.” The judge quoted Article 2.1 and Article 2.5 of the state's constitution in his judgment:[44][45]
On February 21, 2024, the Appellate Division for the Second Judicial Department in New York upheld the lower court's decision upon appeal.[46] In the ruling, associate justice Paul Wooten said, “We determine that this local law was enacted in violation of the New York State Constitution and Municipal Home Rule Law, and thus, must be declared null and void.”[47]
The Supreme Court of the State of New York includes 62 separate courts—one for each county. These courts are the highest trial courts in the state but they are not New York's courts of last resort. The Court of Appeals is the highest court and court of last resort in New York.
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See also[edit]
- Arguments for and against laws permitting noncitizens to vote in the United States
- Debate over the prevalence of noncitizens voting
- Suffrage on the ballot
- Sample Ballot Lookup
- Immigration in the United States
- Immigration Policy
Footnotes[edit]
- ↑ Note that Pew's count of immigrants living in the U.S. illegally included individuals with temporary protection from deportation, like under the Deferred Action for Childhood Arrivals (DACA) program.
- ↑ Pew Research Center, "Key findings about U.S. immigrants," August 20, 2020
- ↑ 3.0 3.1 Cornell Law School, "18 U.S. Code § 611 - Voting by aliens," accessed February 15, 2023
- ↑ 4.0 4.1 4.2 [https://www.nypl.org/sites/default/files/hayduk_-_chapter_2.pdf Democracy For All: Restoring Immigrant Voting Rights in the United States, "The Rise and Fall of Immigrant Voting in U.S. History: 1776 to 1926," accessed June 6, 2024
- ↑ 5.0 5.1 5.2 5.3 5.4 National Immigration Forum, "The Myths and Truths of Noncitizen Voting in the United States," May 7, 2024
- ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 7.0 7.1 San Francisco Elections Office, "San Francisco Voter Information Pamphlet and Sample Ballot," accessed September 26, 2016
- ↑ North Dakotans for Citizen Voting, "Q&A," accessed August 23, 2018
- ↑ North Dakotans for Citizen Voting, "Q&A," accessed June 7, 2024
- ↑ The Dickinson Press, "Change or distraction? Petition seeks to rewrite constitutional language on who can vote," June 17, 2018
- ↑ San Francisco Chronicle, "Judge strikes down San Francisco law allowing noncitizen parents to vote in school elections," July 29, 2022
- ↑ City of San Francisco, "Non-citizen voting rights in local Board of Education elections," accessed June 4, 2024
- ↑ 13.0 13.1 The Washington Post, "House votes to block D.C. bills on noncitizen voting, criminal code," February 10, 2023
- ↑ 14.0 14.1 The Washington Post, "Legal challenge filed against D.C.’s noncitizen voting law," May 13, 2023
- ↑ U.S. District Court for the District of Columbia, "STACIA HALL, et al., v. DISTRICT OF COLUMBIA BOARD OF ELECTIONS, Civil Action No. 23-1261 (ABJ)" March 20, 2024
- ↑ Maryland, "Constitution of Maryland," accessed March 30, 2020
- ↑ Newsweek, "Immigrants are Getting the Right to Vote in Cities Across America," September 13, 2017
- ↑ Town of Barnesville, Maryland, "Town Charter," accessed February 15, 2023
- ↑ Town of Cheverly, "May 3, 2021 Election Information," February 17, 2021
- ↑ Section 3 of the Village of Chevy Chase, "Charter of Incorporation for Section 3 of the Village of Chevy Chase," accessed February 15, 2023
- ↑ Town of Garrett Park, "Charter of the Town of Garrett Park," accessed February 15, 2023
- ↑ Town of Glen Echo, Maryland, "Town Election," accessed February 15, 2023
- ↑ City of Hyattsville, "Elections," accessed February 15, 2023
- ↑ Village of Martin's Additions, "Village Council Elections," accessed February 15, 2023
- ↑ City of Mount Rainier, "Charter with 2017 Election amendments," accessed February 15, 2023
- ↑ Riverdale Park MD, "Town Charter," accessed February 15, 2023
- ↑ Town of Somerset, "Charter," accessed February 15, 2023
- ↑ City of Takoma Park, Maryland, "Register to Vote," accessed February 15, 2023
- ↑ 29.0 29.1 29.2 Seattle Times, "Vermont's Largest City Votes to Allow Nonctiizen Voting," March 9, 2023 Cite error: Invalid
<ref>tag; name "VTdigger" defined multiple times with different content Cite error: Invalid<ref>tag; name "VTdigger" defined multiple times with different content - ↑ Bolts, "Refugee Organizing Helps Spur Noncitizen Voting in Vermont Cities," September 28, 2023
- ↑ Vermont General Assembly, "H.177," accessed February 15, 2023
- ↑ Vermont General Assembly, "H.227," accessed February 15, 2023
- ↑ Berkeley Public Policy Journal, "Spring 2019 Journal: Noncitizen Voting Rights in the United States," March 4, 2019
- ↑ University of Kentucky, "The Right to Vote Under Local Law," accessed February 15, 2023
- ↑ Wisconsin will have a ballot measure related to citizenship requirements for voting in the 2024 elections
- ↑ Cornell Law School, "8 U.S. Code § 1182 - Inadmissible aliens," accessed February 15, 2023
- ↑ Cornell Law School, "8 U.S. Code § 1227 - Deportable aliens," accessed February 15, 2023
- ↑ San Francisco Chronicle, "Judge strikes down San Francisco law allowing noncitizen parents to vote in school elections," July 29, 2022
- ↑ City of San Francisco, "Non-citizen voting rights in local Board of Education elections," accessed June 4, 2024
- ↑ Politico, "New York becomes largest city to grant vote to noncitizens," December 9, 2021
- ↑ The New York Times, "Noncitizens’ Right to Vote Becomes Law in New York City," January 9, 2022
- ↑ NBC News, "New York City Mayor Eric Adams allows noncitizen voting bill to become law," January 10, 2022
- ↑ Democracy Docket, "New York Judge Strikes Down NYC’s Noncitizen Voting Law," June 27, 2022
- ↑ Reuters, "New York judge rules law allowing noncitizens to vote for mayor is unconstitutional," June 27, 2022
- ↑ Democracy Docket, "Full Judgement NYSCEF Doc. No. 174," June 27, 2022
- ↑ Politico, "NYC’s non-citizen voting law ruled unconstitutional on appeal ," February 21, 2024
- ↑ Supreme Court of the State of New York Appellate Division: Second Judicial Department, "Fossella v Adams - D73920," February 21, 2024
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