California v, Trump
Case Overview
A coalition of states sued the Trump administration over its executive order which purports to regulate federal elections by directing the Election Assistance Commission to require a citizenship document to register to vote, mandates federal agencies to turn over voters' personal information to DOGE, and change how states' can administer mail ballots.
The Application
The executive order appears to unilaterally impose voter registration requirements, mandate transfer of voter data to non-governmental entities, and restrict states' mail voting procedures--functions not clearly authorized by statute and traditionally governed by state law.
The Conclusion
The case remains active; resolution depends on whether the court finds the executive order exceeded statutory and constitutional authority.
Case Analysis
Parties & Filing
Nineteen states led by California filed suit April 3, 2025 in D. Mass. (Judge Denise J. Casper) challenging Executive Order 14248, signed March 25, 2025.
What EO 14248 Does
Directs the EAC to require documentary proof of citizenship for voter registration. Mandates federal agency citizenship assessments. Requires DoD proof-of-citizenship on the Federal Post Card Application (military/overseas voting). Directs the AG to enforce against states counting late-arriving absentee ballots. Conditions federal election funding on state compliance.
The Excecutive Order
Section 2(a)
Requires that the National Mail Voter Registration form (authorized under 52 U.S.C. 20508) include documented proof of citizenship, and evidence from the state on which form of proof was provided.
Section 3(d)
Requires the Federal Post Card Application for uniformed and overseas citizens require documentary proof of citizenship and proof of eligibility to vote in the US.
Section 4(a)
Requiring federal election funding to states not complying with these requirements be cut off.
Section 7
The AG shall take action against, and federal election funding is cut off for any state that counts mail in ballots arriving after election day.
Procedural History
Preliminary injunction granted June 13, 2025. Transfer to D.C. (LULAC v. EOP) denied May 9. PI modified July 18 per CASA Inc. V. Trump. Relief limited to plaintiff states. Motion to dismiss denied Sept 17. Defendants appealed to First Circuit Aug 1. Case stayed during government shutdown Oct 14-31. Cross-motions for summary judgment scheduled.
Central Question
Whether Executive Order 14248 exceeds presidential authority under the Elections Clause by unilaterally imposing voter registration requirements, citizenship documentation mandates, and restrictions on state mail ballot administration. Functions Congress assigned to itself and the states, not the President.
APA Question
Whether the directives in EO 14248. Particularly the EAC proof-of-citizenship mandate and the funding conditions. Constitute arbitrary and capricious agency action under the Administrative Procedure Act.
Elections Clause
Article I, § 4: "The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations." Power runs to states and Congress. Not the President.
NVRA / HAVA / UOCAVA
Congress set specific voter registration and election administration requirements through these statutes. NVRA standardized registration. HAVA created the EAC and set provisional ballot rules. UOCAVA governs military and overseas voting. None include the documentary proof-of-citizenship requirements imposed by EO 14248.
APA & Tenth Amendment
The APA constrains executive action to the scope of authority Congress delegated; arbitrary and capricious action is unlawful (5 U.S.C. § 706). The Tenth Amendment reserves powers not delegated to the federal government to the states. Election administration is a core state function.
Wisconsin Exception
The States, except Wisconsin and Minnesota, are required under the NVRA to accept and use the Federal Form to register eligible voters for federal elections. 52 U.S.C. § 20503. Although Minnesota also accepts and uses the Federal Form in accordance with state law, Minn. Stat. § 201.071, Wisconsin does not accept the Federal Form, D.
Elections Clause Analysis
The court found the President lacks independent authority to regulate federal elections. The Elections Clause assigns that power to state legislatures, with Congress as the override. Not the executive. EO 14248 attempts to impose voter registration requirements (documentary proof of citizenship) that Congress explicitly chose not to include when it enacted NVRA and HAVA. The President cannot do by executive order what Congress declined to do by statute.
Funding Conditions & UOCAVA
The EO conditions federal election funding on state compliance with requirements Congress never authorized. A coercive mechanism with no statutory basis. The DoD proof-of-citizenship mandate on the Federal Post Card Application conflicts with UOCAVA, which Congress designed to reduce barriers for military and overseas voters, not add them. The AG enforcement directive against states counting late absentee ballots overrides state-law deadlines Congress left to state discretion.
PI Scope & CASA Modification
The preliminary injunction originally blocked EO 14248 nationwide. After CASA Inc. V. Trump, the PI was narrowed July 18 to cover only the nineteen plaintiff states. Limiting relief but not altering the court's finding that the EO likely exceeds presidential authority. The motion to dismiss was denied Sept 17, reinforcing the merits finding.
Not Ripe?
The government argues repeatedly that because the President has not yet actually withheld anything or enforced anything, and won't until an election actually occurs, there is no injury. The Court rejects this argument finding that pre-enforcement review of a threatened government action is appropriate if the government’s threat of enforcement is “sufficiently imminent.” The court also recognizes the current conflict with state law and restriction on funding as an ongoing harm.
Current Status
Preliminary injunction granted June 13, 2025, blocking EO 14248 in plaintiff states. Motion to dismiss denied. Government appeal pending at the First Circuit (filed Aug 1, 2025; brief filed Oct 7). Cross-motions for summary judgment scheduled at the district court level. Related case 26-cv-11581 (EO 14399) filed in the same court before Judge Talwani.
Permanent Injunction
Permanent Injunction issued June 24, 2026 against sections 2(a), 3(d), 4(a), 7(a) and 7(b). Court also grants declaratory judgment. EXCEPT WISCONSIN (See Rules)
https://storage.courtlistener.com/recap/gov.uscourts.mad.282905/gov.uscourts.mad.282905.190.0.pdf
July 10 - Joint Stipulation
There are 19 plaintiffs in this case, all states. But six of those plaintiffs are not "ballot receiving states" so section 7(b) of the executive order never applied to them in the first place.
So when the injunction dropped on June 24, the part of it that stopped the trump administration from enforcing section 7(b) against the plaintiffs never applied to those six states.
Today, everyone agrees to dismiss the part of the case suing on behalf of those 6 states to stop enforcement of section 7(b), because it's irrelevant.
https://storage.courtlistener.com/recap/gov.uscourts.mad.282905/gov.uscourts.mad.282905.192.0.pdf
July 13 - Order and Judgment
The Court DECLARES that §§ 2(a), 3(d), 4(a), 7(a) and 7(b) of the Executive Order are unconstitutional and void because they are ultra vires and violate the separation of powers under the United States Constitution; and The Court DECLARES that § 2(a) of the Executive Order is inconsistent with the NVRA, and that § 3(d) of the Executive Order is inconsistent with UOCAVA. https://storage.courtlistener.com/recap/gov.uscourts.mad.282905/gov.uscourts.mad.282905.194.0.pdf
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