JURIST - Paper Chase: Eleventh Circuit upholds Georgia voter ID law

[JURIST] The US Court of Appeals for the Eleventh Circuit [official website] on Wednesday upheld [opinion, PDF] a Georgia law that requires voters to present government-issued photo identification in order to vote. The suit [complaint, PDF] was filed by two elderly voters in Georgia, the National Association for the Advancement of Colored People (NAACP) [advocacy website], and other civil rights groups that argued that the legislation makes it difficult for minorities, the elderly, and the impoverished to participate in elections. In the opinion, Judge Bill Pryor affirmed the district court's decision, saying:

The inability to locate a single voter who would bear a significant burden provides significant support for a conclusion that the Photo ID requirement does not unduly burden the right to vote. The insignificant burden imposed by the Georgia statute is outweighed by the interests in detecting and deterring voter fraud.

The decision relied to a large extent on the April 2008 Supreme Court ruling in Crawford v. Marion County Election Board [opinion, PDF; JURIST report], which held that Indiana's controversial voter identification statute did not put an undue burden on the right to vote and therefore did not violate the US Constitution. In October 2006, the Supreme Court ruled in a per curiam opinion [text, PDF] that Arizona could enforce its voter ID law [JURIST report], which requires voters to show government-issued voter ID cards at the polls. Voter ID laws have also been upheld in Michigan, but struck down in Missouri. Currently, more than 20 states require some form of voter identification at the polls.