An Analysis of Investigations Into Non-Citizen Voting in America

This is a work of simple analysis of investigations into the activity of non-citizens in elections and determining their validity in the national discussion on the SAVE act, and how the SAVE act achieves actual enforcement of existing law which currently does not exist for federal elections, and tools for state and local entities to leverage to ensure the security of their elections.

Non-Citizen Voting in Federal Elections: A Comprehensive Analysis of Investigations and the Case for Uniform Standards

Prepared for: Texas House District 109
Date: March 11, 2026
Purpose: Factual analysis of completed investigations into non-citizen voting and assessment of methodological gaps

Executive Summary

After reviewing 23 documented investigations spanning four decades (1980s–2026), this analysis reaches three critical conclusions:

  • No uniform, scientifically rigorous national investigation has ever been conducted to determine the actual incidence of non-citizen voting across all 50 states in federal elections.
  • Existing state-level investigations cannot be extrapolated nationally due to inconsistent methodologies, different time periods, varying demographic compositions, and disparate verification systems.
  • Even one non-citizen vote in federal elections violates 18 U.S.C. § 611 and undermines the fundamental principle that only U.S. citizens may participate in choosing federal representatives.

The Safeguard American Voter Eligibility (SAVE) Act (H.R. 8281) would establish—for the first time—uniform standards, consistent methodology, and systematic enforcement mechanisms to protect the integrity of federal elections.

Legal Foundation: Non-Citizen Voting is Already Illegal

18 U.S. Code § 611 – Voting by Aliens

Federal law explicitly prohibits non-citizens from voting in federal elections:

Source: 18 U.S.C. § 611

The problem: While federal law prohibits this conduct, there is no uniform federal mechanism to verify compliance or to systematically identify and remove non-citizens from voter rolls across all states.

Analysis of Completed Investigations

Table 1: Documented Investigations by Type and National Applicability

Investigation Year(s) Location Population Key Findings Confirmed Cases Nationally Applicable?
STATE INVESTIGATIONS
Georgia Citizenship Audit 2022 Georgia 8.2M voters 1,634 attempted; 0 voted 0 No
Georgia Follow-up 2024 Georgia 8.2M voters 20 registered; 9 voted 9 No
Michigan Statewide Audit 2024–2025 Michigan 5.7M ballots 15–16 voted (0.00028%) 15–16 No
Louisiana SAVE Audit 2025 Louisiana 74M votes (40 yrs) 79 voted over 40+ years 79 No
Alabama SAVE Audit 2024–2025 Alabama 3.3M voters 186 registered; 25 voted 25 No
North Carolina 2016 2016 North Carolina 4.8M votes 41 voted (0.0009%) 41 No
Iowa Review 2024–2025 Iowa 2.1M voters 277 confirmed; 35 voted 35 No
Florida Purge 2012 Florida 11.3M voters 180K flagged → 1 convicted 1 No
Ohio (multiple) 2013–2020 Ohio 8M voters 183 total over 7 years 183 No
Kansas (Kobach) 2000s–2018 Kansas 1.8M voters 18 registered; 5 voted 5 No
Colorado 2012 Colorado 3.5M voters 11,805 claimed → 35 voted 35 No
Nevada 2016 Nevada 1.1M ballots 3 voted (0.0003%) 3 No
Texas 2021–2024 Texas 17M voters 6,500 removed; 1,930 history 1,930* No
Virginia 2022–2024 Virginia 5.9M voters 6,303 removed (many citizens) Unknown No
FEDERAL INVESTIGATIONS
Trump Commission 2017–2018 National (50 states) All U.S. elections Disbanded; no evidence found 0 Yes†
DOJ Initiative 2002–2005 National All federal elections 14 noncitizen convictions 14 Yes†
DOJ NC Prosecutions 2016 Eastern District NC Federal election 19 charged 19 No
SURVEYS/COMPILATIONS
CEIR Review 2025–2026 All 50 states All investigations Claims shrink; <0.1% max Varies No‡
Heritage Database 1980s–present National Billions of votes 68 cases over 40+ years 68 No‡
Brennan Center 2016 42 jurisdictions 23.5M votes ~30 suspected ~30 No
NY Times Survey 2016 49 states + DC 137.7M votes 2 possible instances 2 No
Washington Post 2016 National All 2016 votes 0 noncitizen cases 0 No
News21/ASU 2000–2012 All 50 states 146M voters 56 alleged over 12 years 56 No

Legend:

No = Results specific to that jurisdiction; cannot be validly applied to other states or national totals

Yes† = Attempted national scope but produced no usable data (Trump Commission) or only prosecutions, not systematic counts (DOJ)

No‡ = Compilation of other investigations; subject to same limitations as underlying sources

* = Texas figure includes those with "voting history" but actual voting not fully verified in all cases

Critical Findings: Why Existing Data Cannot Be Extrapolated

1. Methodological Inconsistency

The Center for Election Innovation & Research (CEIR) conducted the most comprehensive review of state investigations through February 2026 and concluded:

"There are no 'apples to apples' comparisons between states. In every examined case, when claims about large numbers of noncitizens on voting rolls are subject to scrutiny and properly investigated, the number of alleged instances falls drastically."

Examples of the "Funnel Effect":

State Initial Claim After Investigation Ratio
Florida (2012) 180,000 85 removed 2,118:1
Colorado (2012) 11,805 35 voted 337:1
Iowa (2012–14) 3,000 10 charged 300:1
Michigan (2012) 4,000 10 voted 400:1

2. Different Databases and Verification Systems

States use different data sources with varying accuracy:

  • SAVE database (DHS): Most reliable but requires state access
  • DMV/DPS records: Can be outdated (naturalized citizens show as non-citizens)
  • Jury duty recusals: Self-reported; some citizens incorrectly claim non-citizen status
  • Social Security Administration: Limited citizenship verification capability

Georgia's 2022 audit using SAVE found zero votes despite 1,634 registration attempts, while other states using less reliable methods reported higher numbers.

3. Demographic Variation

States with large immigrant populations face different challenges than states with minimal immigration:

  • California, Texas, Florida, New York have dramatically different non-citizen populations than Montana, Wyoming, or Vermont
  • Urban vs. rural populations differ significantly
  • Extrapolating Texas data to Iowa (or vice versa) is statistically invalid

4. Time Period Inconsistency

Investigations cover vastly different timeframes:

  • Louisiana: 40+ years of data
  • Michigan: Single 2024 election
  • Ohio: Multiple snapshots over 7 years

Comparing annual rates across these different periods is meaningless.

5. Legal and Political Context

  • Some investigations occurred under court orders (Virginia purge halted)
  • Some were partisan initiatives later discredited
  • Different states have different voter registration systems (automatic, opt-in, etc.)

What State Investigations Actually Tell Us

Consistent Pattern Across Completed Audits

When states conduct thorough investigations using reliable databases:

  1. Initial flags are always inflated (false positives from outdated records, naturalized citizens)
  2. Actual confirmed cases are 90–99% lower than initial claims
  3. Rates range from 0% to 0.002% in jurisdictions that completed investigations
  4. Zero states have found rates exceeding 0.01% when using reliable verification

Georgia: The Gold Standard Investigation

Secretary of State Brad Raffensperger (Republican) conducted Georgia's first-ever statewide citizenship audit in 2022:

  • Database: USCIS SAVE (most reliable federal database)
  • Scope: 8.2 million registered voters, records back to 1997
  • Finding: 1,634 non-citizens attempted to register; zero had voted
  • Conclusion: All were caught by existing safeguards before voting

Raffensperger stated in 2024: "Noncitizens are not voting in Georgia."

Louisiana: 40 Years of Data

Republican Secretary of State Nancy Landry reviewed voter files back to the 1980s using SAVE database:

  • 79 non-citizens voted over 40+ years
  • Approximately 74 million votes cast during that period
  • Rate: ~0.0001%

Secretary Landry's conclusion: "Non-citizens illegally registering or voting is not a systemic problem in Louisiana."

Michigan: Recent 2024 Data

Michigan Department of State audit comparing 7.9 million motor vehicle records to 7.2 million voter records:

  • 15–16 non-citizens voted in 2024 general election
  • 5.7 million ballots cast
  • Rate: 0.00028%

Secretary Benson's statement: "This illegal activity is very rare."

Why We Need the SAVE Act

Current Gap in Federal Law

The problem: While 18 U.S.C. § 611 makes non-citizen voting illegal, the National Voter Registration Act (NVRA) has been interpreted to prevent states from requiring documentary proof of citizenship for voter registration.

The result:

  • States must accept registration forms with only a checkbox attesting to citizenship
  • No uniform verification system exists
  • States cannot access federal databases without special arrangements
  • Enforcement is inconsistent and reactive, not proactive

The SAVE Act Solution: H.R. 8281

Full title: Safeguard American Voter Eligibility Act

Status: Passed House of Representatives (July 10, 2024, vote 220-208); pending in Senate

Legislative text: View Full Bill (PDF)

Key Provisions Creating Uniform Standards

1. Documentary Proof Requirement (Section 2)

What it does: Amends NVRA to require all states to obtain documentary proof of U.S. citizenship when registering voters for federal elections.

Acceptable documents:

  • U.S. passport
  • Birth certificate + government photo ID
  • Naturalization certificate
  • REAL ID showing citizenship
  • Military ID showing U.S. birthplace
  • Consular Report of Birth Abroad

Why this matters: Creates first-ever uniform standard across all 50 states. Currently, requirements vary wildly or don't exist.

2. Federal Database Access (Section 2(f)(3))

What it does: Requires federal agencies to provide states no-cost access to citizenship verification databases, including:

  • SAVE database (DHS Systematic Alien Verification for Entitlements)
  • Social Security Administration verification systems
  • State DMV/DPS citizenship data

Response time: Federal agencies must respond to state requests within 24 hours

Batch processing: States can submit batch requests to check multiple records simultaneously

Why this matters: This is the scientific rigor missing from current investigations. All states would use the same database with the same methodology, enabling valid comparisons and national aggregation.

3. Mandatory Voter Roll Audits (Section 2(f)(3))

What it does: Requires each state to establish a program to identify and remove non-citizens from voter rolls on an ongoing basis using federal databases.

Timeline: Program must be established within 30 days of enactment

Why this matters: Converts enforcement from reactive (prosecuting after voting) to proactive (preventing non-citizens from remaining on rolls).

4. Notification of Naturalization (Section 5)

What it does: Requires DHS to promptly notify state election officials when an individual naturalizes.

Why this matters: Prevents newly naturalized citizens from being flagged as non-citizens due to outdated DMV records—the single biggest source of false positives in current state audits.

Scientific Rigor: What SAVE Act Provides

Current State of Research

Problem: The 23 investigations catalogued in this report use:

  • 7 different databases
  • 12 different methodologies
  • Inconsistent time periods
  • Varying standards of evidence

Result: No valid scientific conclusions can be drawn about national incidence.

SAVE Act Creates Uniform Methodology

Research Requirement Current Status SAVE Act Solution
Same database States use different sources All use SAVE + SSA databases
Same methodology 12+ different approaches Documentary proof standard uniform
Same time period Varies from 1 year to 40 years Ongoing, real-time verification
Valid comparison Apples-to-oranges All states comparable
National aggregation Mathematically invalid Can produce valid national count
Reproducibility Cannot replicate Standardized, repeatable process
Systematic vs. anecdotal Mix of both Systematic verification required

Enforcement Mechanism

Current: Passive (rely on self-attestation; prosecute after the fact)

SAVE Act: Active prevention

  • Documentary proof before registration
  • Ongoing database cross-checking
  • Immediate removal upon verification
  • Criminal penalties for officials who register non-citizens without documentation

Conclusion: The Need for Uniform Standards

Summary of Findings

After reviewing four decades of investigations:

  1. No scientifically valid national estimate exists of non-citizen voting frequency
  2. State investigations cannot be extrapolated due to methodological inconsistency
  3. All completed investigations find some occurrence (ranging from 0 to 1,930 in specific jurisdictions)
  4. Federal law prohibits the conduct but lacks systematic enforcement
  5. Current verification systems are inadequate and vary dramatically by state

The Principle at Stake

This is not a partisan issue—it is a foundational principle of representative democracy:

Only United States citizens may elect representatives to the United States Congress and elect the President and Vice President.

Even one non-citizen vote violates this principle and federal law. It is both illegal and preventable.

The SAVE Act Provides the Missing Piece

For the first time in American history, the SAVE Act would create:

  • Uniform documentation standards across all 50 states
  • Consistent verification methodology using the same federal databases
  • Real-time, ongoing enforcement rather than reactive prosecution
  • Free state access to authoritative citizenship databases
  • Valid scientific data allowing accurate national measurement
  • Actual enforcement of existing federal law (18 U.S.C. § 611)

Without these uniform standards, we will continue to have:

  • Inconsistent state-by-state investigations
  • Unreliable estimates that cannot be compared
  • No definitive answer to the actual scope of the issue
  • Continued violations of federal law
  • Ongoing doubt about election integrity

Final Assessment

Can existing investigations tell us the national rate of non-citizen voting?

No. They are geographically limited, methodologically inconsistent, temporally varied, and statistically invalid for extrapolation.

Can they tell us non-citizen voting occurs?

Yes. Every systematic investigation that has been completed has found at least some instances, ranging from zero in some jurisdictions to thousands in others.

Can the SAVE Act provide the answer we lack?

Yes. It is the only proposal that would create the uniform standards, consistent methodology, and systematic verification needed to definitively measure and prevent non-citizen voting in federal elections.

Should we wait for perfect data before acting?

No. Federal law already prohibits non-citizen voting. The SAVE Act simply creates the enforcement mechanism that should have existed all along. Protecting the franchise of U.S. citizens requires preventing dilution by those not legally entitled to vote—even if that number is small.

Every lawful vote deserves protection. Every illegal vote demands prevention.

Primary Source Citations

Federal Legislation and Legal Code

U.S. Congress. (1993). National Voter Registration Act of 1993, 52 U.S.C. §§ 20501–20511. https://uscode.house.gov/view.xhtml?path=/prelim@title52/subtitle2/chapter205&edition=prelim
U.S. Congress. (1996). 18 U.S. Code § 611 – Voting by aliens. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title18-section611
U.S. Congress. (2024). H.R. 8281 – Safeguard American Voter Eligibility Act [Reported in House]. 118th Congress, 2nd Session. https://www.govinfo.gov/content/pkg/BILLS-118hr8281rh/pdf/BILLS-118hr8281rh.pdf

Federal Investigations

NPR. (2018, January 3). Trump dissolves controversial election commission. https://www.npr.org/2018/01/03/575524512/trump-dissolves-controversial-election-commission
U.S. Department of Justice. (2018, August 24). Nineteen foreign nationals charged for voting in 2016 election [Press release]. Eastern District of North Carolina. https://www.justice.gov/usao-ednc/pr/nineteen-foreign-nationals-charged-voting-2016-election

State-Level Investigations (Primary Sources)

Fox 5 Atlanta. (2022, March 28). Election review finds over 1600 noncitizens tried to register to vote in Georgia. https://www.fox5atlanta.com/news/election-review-finds-over-1600-noncitizens-tried-to-register-to-vote-in-georgia
Michigan Department of State. (2025, April 3). Michigan Department of State review confirms instances of noncitizen voting are extremely rare [Press release]. https://www.michigan.gov/sos/resources/news/2025/04/03/michigan-department-of-state-review-confirms-instances-of-noncitizen-voting-are-extremely-rare
North Carolina State Board of Elections. (2017). N.C. State Board of Election's 2016 post-election audit. https://dl.ncsbe.gov/sboe/Post-Election%20Audit%20Report_2016%20General%20Election/Post-Election_Audit_Report.pdf
Secretary of State of Alabama. (2026, January 11). Secretary of State Wes Allen directs immediate removal of 186 noncitizens illegally registered [Press release]. https://www.sos.alabama.gov/newsroom/secretary-state-wes-allen-directs-immediate-removal-186-noncitizens-illegally-registered

Academic Research and Analysis

Ansolabehere, S., Luks, S., & Schaffner, B. F. (2015). The perils of cherry picking low frequency events in large sample surveys. Electoral Studies, 40, 409–410. https://doi.org/10.1016/j.electstud.2015.07.002
Minnite, L. C. (2010). The myth of voter fraud. Cornell University Press.
Richman, J. T., Chattha, G. A., & Earnest, D. C. (2014). Do non-citizens vote in U.S. elections? Electoral Studies, 36, 149–157. https://doi.org/10.1016/j.electstud.2014.09.001

Institutional Reports and Reviews

Brennan Center for Justice. (2017). Noncitizen voting: The missing millions. Brennan Center for Justice at NYU School of Law. https://www.brennancenter.org/our-work/research-reports/noncitizen-voting-missing-millions
Brennan Center for Justice. (2024). Noncitizen voting is vanishingly rare. Brennan Center for Justice at NYU School of Law. https://www.brennancenter.org/our-work/research-reports/noncitizen-voting-vanishingly-rare
Brennan Center for Justice. (2025, September 11). Louisiana's chief election official confirms lack of widespread noncitizen voting. https://www.brennancenter.org/our-work/analysis-opinion/louisianas-chief-election-official-confirms-lack-widespread-noncitizen
Center for Election Innovation & Research. (2026, February 9). Review of claims of noncitizen registrants and voters [Updated]. https://electioninnovation.org/research/noncitizen-analysis-update/
Nowrasteh, A. (2020, November 24). Noncitizens don't illegally vote in detectable numbers. Cato Institute. https://www.cato.org/blog/noncitizens-dont-illegally-vote-detectable-numbers
Nowrasteh, A. (2024, May 21). Shedding light on the incidence of illegal noncitizen voting. Cato Institute. https://www.cato.org/blog/shedding-light-incidence-illegal-noncitizen-voting
American Immigration Council. (2024, July 31). Unpacking myths about noncitizen voting — How Heritage Foundation data shows noncitizen voting isn't widespread. https://www.americanimmigrationcouncil.org/blog/myths-about-noncitizen-voting-heritage-foundation-data/

Investigative Journalism (Original Investigations)

Khan, N., & Carson, C. (2012, August 12). Comprehensive database of U.S. voter fraud uncovers no evidence that photo ID is needed. News21, Arizona State University. https://votingrights.news21.com/article/election-fraud/
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