IRLI submitted a friend-of-the-court brief in support of the State of Arizona in a lawsuit challenging the state’s law requiring proof of citizenship to register to vote on federal forms and proof of identification at the polls. IRLI’s brief provided powerful arguments why the court should uphold the law. The U.S. Court of Appeals for the Ninth Circuit upheld the voter identification requirement, but struck down the voter registration provision as preempted by the National Voter Registration Act of 1993. Gonzalez v. Ariz., 677 F.3d 383 (9th Cir. 2012).