Missouri Judge Upholds Strict Photo ID Requirements for Voting
Missouri Judge Jon E. Beetem yesterday upheld the state’s strict photo ID requirements for in-person voting after finding the new rules do not violate the Missouri Constitution’s guarantee of the fundamental right to vote.
Monday’s decision comes just over a year after Beetem held a trial in a lawsuit brought by the League of Women Voters of Missouri, Missouri NAACP and three voters who alleged the burdensome identification rules infringe on the right to vote and the right to equal protection. The groups have already indicated their plan to appeal the decision in the near future.
Beetem’s 39-page ruling concluded that both the organizational and individual voter plaintiffs lacked standing since they failed to prove they are harmed by the state’s voter ID provisions or demonstrate that they must divert resources as a direct result of the rules. Beetem also found that the challenged requirements “do not present a substantial or severe burden upon the right to vote” and determined that the law “furthers the State’s interest in deterring voter fraud, such as voter impersonation.”
In June 2022, Missouri’s Republican-controlled Legislature overhauled the state’s previous voter identification requirements as part of an omnibus voter suppression package known as House Bill 1878, which lawmakers passed in the name of “election integrity.”
The relatively recent law limits acceptable forms of identification to government-issued, non-expired state or federal photo IDs — eliminating the option for voters to provide several types of previously valid secondary identification, such as a voter registration card, Missouri student ID, out-of-state driver’s license or current utility bill.
Under H.B. 1878’s new requirements, voters who fail to present one of the acceptable forms of identification at the polls may cast a provisional ballot, which will only be counted if they return within the same day with a valid ID or if the signature on their ballot is matched with the one in the registration file — an error-prone process that the plaintiffs argued leads to over-rejection of ballots.
Although Missouri provides voters with the opportunity to obtain a cost-free photo ID, the plaintiffs maintained that such assistance fails to alleviate the burden caused by the significant time and effort required to navigate the process. The plaintiffs further averred that Missouri’s own data indicate that over 200,000 voters lack a state photo ID.
The Missouri NAACP’s lawsuit had argued the contested requirements disproportionately disenfranchise voters of color, student voters, elderly voters, voters with disabilities, unhoused voters and rural voters, for whom obtaining the proper form of identification is often more difficult.
But Beetem, in yesterday’s ruling, said the photo ID provisions only pose a minimal burden on voters and referred to the plaintiffs’ concerns about high provisional ballot rejection rates as “purely speculative.”
“Evidence at trial confirms that rejection rates for provisional ballots are low, and the rates specifically for signature-mismatch are exceedingly low,” the order reads.
The opinion also cited a 2016 voter-approved constitutional amendment that authorized the state to impose photo ID requirements. That H.B. 1878 implemented such a constitutionally authorized photo ID requirement “undercuts all of Plaintiffs’ constitutional arguments” against the statute, Beetem said.
The Missouri Supreme Court previously struck down legislatively-enacted photo ID requirements in both 2006 and 2020, holding they violate the state constitution.
Attorneys from the ACLU of Missouri and the Missouri Voter Protection Coalition, who represent the plaintiffs, said in a statement that they are “disappointed with the decision and will appeal to protect Missourians’ fundamental right to vote.”
“The evidence at trial showed the significant burdens some voters face to obtain the limited form of ID this law requires to vote [and] further showed that the voter ID restrictions do not fix actual election problems or make our elections more secure. The Missouri Supreme Court will ultimately review this decision… and hopefully conclude, again, that these restrictions improperly limit valid Missouri voters from participating in the democratic process,” the statement added.
In a post on X, Missouri Attorney General Andrew Bailey (R) called the ruling a “HUGE win for election security.”