Federal judge dismissed Indiana proof-of-citizenship voter suit on standing grounds, leaving no relief before midterms

On September 10, 2026, U.S. District Judge Matthew P. Brookman of the Southern District of Indiana dismissed a lawsuit brought by the League of Women Voters of Indiana, Common Cause Indiana, Hoosier Asian American Power, and Exodus Refugee Immigration against Indiana Secretary of State Diego Morales and other election officials, challenging two state laws — House Enrolled Acts 1264 and 1680 — that require certain registered and prospective voters to submit documentary proof of citizenship after a data match flags them as having once held a temporary, noncitizen-eligible ID. Brookman held that the plaintiff organizations lacked standing, ruling that under the U.S. Supreme Court's 2024 decision in FDA v. Alliance for Hippocratic Medicine, an organization cannot establish standing merely by diverting its own resources to counteract a law's effects, and that the plaintiffs had failed to identify the "core business activities" the new test requires them to show are impaired. He denied the plaintiffs' pending motion for a preliminary injunction as moot given the dismissal, and did not rule on whether the challenged laws themselves violate the National Voter Registration Act or the Civil Rights Act of 1964.

The dismissal was issued without prejudice, giving the organizations 28 days to file an amended complaint, but it denies them any path to a preliminary injunction before Indiana's November 2026 midterm elections. A June 2026 filing in the same case found Indiana had already canceled the registrations of 981 existing voters and rejected 644 new registrants — about 62 percent of those processed under the challenged laws — in part because naturalized citizens are never removed from the state Bureau of Motor Vehicles list used to flag voters for the citizenship check. Plaintiffs' counsel said the ruling leaves thousands of eligible Indiana voters, disproportionately naturalized and derived U.S. citizens, at risk of wrongful removal from the rolls with no court-ordered relief before Election Day.