Do Photo IDs Help Prevent Vote Fraud?

Presenting photo identification is not an onerous requirement for voting. But there's next to zero evidence that fraud is a problem.

Hal Hildebrand asks, “Do photo IDs help prevent vote fraud?” Further, he specifically wishes that I would “make this a cause.”

As grist, he links a blog post by Jeremy Epstein asking, well, “Do photo IDs help prevent vote fraud?” The piece, rather unhelpfully, does not address the title question in any useful way. Instead, he contends that:

  • Allowing the use of voter registration cards or Social Security cards — neither of which have photos! — doesn’t help.
  • Poll workers aren’t really trained to compare ID photos with faces.
  • Drivers licenses and US Passports are valid for a number of years, so some people won’t look all that much like their photos.

To which I respond: photo ID really should have photos on them — I mean, it’s right there in the name — and poll workers should receive a regimen of training at least as exhaustive as the average nightclub doorman.

As an intuitive matter, I’m flummoxed by the idea that being required to possess and show voter identification is either burdensome or somehow particularly intimidating to members of racial minority groups. Indeed, like Epstein, I live and vote in Virginia. I’m routinely asked to hand over my ID to the little old ladies at the check-in table and have thus far had little difficulty persuading them that I’m the guy in the photo.

Further, to the extent that people are trying to vote by claiming to be someone they’re not, it’s intuitively obvious that a requirement to present photo ID would be at least a modest–though hardly insurmountable or foolproof–deterrent.

There’s just a wee problem with all of this: There’s next to zero evidence that voter fraud of the type that could be deterred by photo ID is a significant problem in the United States.

An October 2006 report to the U.S. Election Assistance Commission found, as reported by USA Today, that “most fraud occurs in the absentee ballot process, such as through coercion or forgery.”

Similarly, a five-year effort by the Bush Justice Department “turned up virtually no evidence of any organized effort to skew federal elections,” according to reporting by the NYT. While 86 people were convicted of crimes related to elections, they were mostly felons and illegal aliens who voted despite not being eligible.  They found no evidence of widespread conspiracy, much less double voting or other types of fraud that an ID requirement would prevent.

It makes sense when you stop and think about it. The minuscule gain in voting a second time while claiming to be someone else is almost surely not worth the risk of getting caught. And there are much easier ways of gaming the system, such as filling out absentee ballots for nursing home residents and others under undue influence.

Now, people have irrational fears and often aren’t swayed by empirical evidence.  Since presenting photo ID is such an easy thing to do, it might be justifiable as a requirement if it truly boosts public confidence in the sanctity of the ballot box. But it will have next to no impact on actual fraud–since there’s next to no actual fraud of the type the laws seek to deter.

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James Joyner
About James Joyner
James Joyner is Professor and Department Head of Security Studies at Marine Corps University's Command and Staff College. He's a former Army officer and Desert Storm veteran. Views expressed here are his own. Follow James on Twitter @DrJJoyner.

Comments

  1. Jay Tea says:

    James, True The Vote in Texas has been doing some very interesting work. And if you Google up ACORN voter fraud, you’ll find quite a few convictions of ACORN officials and “volunteers” for actual voter fraud — not just voter registration fraud.

    The voter registration fraud has many possible benefits. The first, of course, is to facilitate actual voter fraud. The second is to discredit the election results, by pointing out how low the turnout was compared to the registered voters. The third is to skew polling results by flooding the rolls of registered Democrats in a district with bogus numbers. A fourth is to serve as a rationale for more get-out-the-vote money, as all they have to do is show how low the turnout was to justify asking for more funds.

    Everyone focuses on the first, and ignores the rest.

    But yeah, I think voting is more meaningful than buying groceries or giving blood, and they demand an ID there. I WANT to be asked for my ID, because I WANT my franchise protected.

    J.

  2. legion says:

    I think a more appropriate question would be: “Is voter fraud actually a problem we’re having?” If somebody’s got evidence it is, I’d like to see it…

  3. Hal Hildebrand says:

    So, I think you’re misreading Epstein’s post. As numerous security experts have blogged about, there’s a fundamental problem with ids. One problem right off the bat is the relation to the photo to the person in front of you. My previous passport was 10 years old before I renewed it. When I took the photo I had really long hair that was pulled back into a pony tail all the time. I looked like I was bald in the photo. Immigration officials would scratch their heads looking at the photo and looking at me when travelling internationally. Luckily, it was indeed a valid passport and those officials have the equipment and the training to spot fraudulent documents. But there were a lot of times when I got special treatment simply because my photo didn’t look like me in person.

    This is not an uncommon issue, and as Epstein points out, some people are simply lousy as hell at matching photos to faces. So your argument boils down to “But they should be!” which doesn’t strike me as much of an argument.

    But the real point of Epstein’s post is that there is no way to train anyone to know all the possible forms of ids that are accepted. This has nothing to do with matching photos to faces, but is in fact a really fundamental issue with identity checks in general. For example, if a police officer shows up and shows me his badge as proof of his identity as an officer, how am I supposed to know whether he has a convincing but fake id or the real thing? When exactly was I supposed to be trained to spot a fake police ID? Further, spotting these fakes usually takes equipment to verify fraud protection features of the ID.

    So the issue he’s really tackling is that having a photo ID that you can’t verify – even though you can match the photo to the person – isn’t really providing any security what so ever. It’s security theatre, and bad theatre at that. There’s simply no way – for example – that any volunteer (and they are volunteers) can be trained in all the company IDs that voters could possibly use. It’s just not possible. So someone shows up with a company ID and viola! the photo matches. But are they who they say they are? We’re still no closer to answering that question.

    In summary, photos aren’t the real problem. Verifiable credentials are. And given our collective aversion to any kind of verifiable credentials – especially on the right, I might add – the photo ID preventing non measurable voter fraud is worse than a straw man…

  4. steve says:

    Jay Tea- This is a minor interest of mine. I have never found much voter fraud at all. What exactly did you Google? If the links are convenient, please forward.

    I don’t want carrhy around one more darn card if I don’t need to do so. I would like evidence that it is a problem before we solve it.

    Steve

  5. ponce says:

    ” Since presenting photo ID is such an easy thing to do, it might be justifiable as a requirement if it truly boosts public confidence in the sanctity of the ballot box.”

    Lord knows there are no Americans with mobility problems that make it difficult for them to secure photo ID.

  6. You obviously don’t live in St. Louis.

  7. pylon says:

    Jay Tea seems to (perhaps on purpose) confuse voter registration fraud, where people fraudulently present registrations in order to collect the fees offered by groups like ACORN with voter fraud, in which someone pretends to be someone else in order to cast a presumably extra vote.

    The former seems to me to be a ripoff of ACORN, not the other waya round (not that ACORN shouldn’t have had better controls).

    The latter is a miniscule problem due to its very nature. A single extra vote can hardly affect an election, and voter ID type fraud can’t exist on a large scale. The only voter fraud I can see affecting an election is by computer interference (ohio?).

  8. michael reynolds says:

    The idea that people in this country would actually commit fraud in order to cast a vote is just kind of sad. You can’t get Americans to vote legally. It’s like an 80 year-old grandma who worries that men are ogling her.

    My passport, by the way, shows me looking a lot like the long lost Soprano brother. As opposed to the avatar you see which shows me for what I am, a man with an insect’s compound eyes. It can be very confusing.

  9. mantis says:

    And if you Google up ACORN voter fraud, you’ll find quite a few convictions of ACORN officials and “volunteers” for actual voter fraud — not just voter registration fraud.

    Really? I googled “ACORN voter fraud convictions” instead, to narrow it down. The search resulted in links to many stories of convictions for voter registration fraud, but I can’t find any of actual voter fraud. I did find this from 2008 though:

    There’s no evidence of any such democracy-destroying fraud. Here’s what is true: In recent years, ACORN employees have been investigated multiple times for voter registration fraud. ACORN workers have been convicted of submitting false voter registration forms in Colorado Springs in 2005, Kansas City, Mo., in 2006 and King County, Wash., in 2007. ACORN’s Las Vegas office was raided by a state criminal investigator on Oct. 7, 2008. ACORN workers are also the subjects of ongoing investigations in Wisconsin, Missouri, Ohio, Pennsylvania and Indiana. The Indiana investigation started in early October and may involve thousands of fraudulent registration forms.

    But so far ACORN itself has not been officially charged with any fraud. Aside from the heated charges and counter-charges, no evidence has yet surfaced to show that the ACORN employees who submitted fraudulent registration forms intended to pave the way for illegal voting. Rather, they were trying to get paid by ACORN for doing no work. Dan Satterberg, the Republican prosecuting attorney in King County, Wash., where the largest ACORN case to date was prosecuted, said that the indicted ACORN employees were shirking responsibility, not plotting election fraud.

    Why don’t you provide actual links to all of these fraudulent voters you speak of, instead of just saying “Google it?”

    The voter registration fraud has many possible benefits. The first, of course, is to facilitate actual voter fraud. The second is to discredit the election results, by pointing out how low the turnout was compared to the registered voters. The third is to skew polling results by flooding the rolls of registered Democrats in a district with bogus numbers. A fourth is to serve as a rationale for more get-out-the-vote money, as all they have to do is show how low the turnout was to justify asking for more funds.

    Jay misses the most obvious explanation, of course. That some registration workers don’t want to do the actual work, and write false registrations so they still get paid. No, that can’t be it. It must be a conspiracy!

    Everyone focuses on the first, and ignores the rest.

    Cute, coming from the guy who ignores the most likely reason.

  10. michael reynolds says:

    mantis:

    Jay doesn’t do facts.

    He repeats something he read on Drudge or heard on Fox. Then, when challenged, he runs away.

  11. PJ says:

    What you actually find convictions for is voter suppression, like phone jamming for example.

  12. James Joyner says:

    @Hal:

    I’m sure that photo ID isn’t a cure-all. But we use it for everything from airport security to age verification at liquor stores to foreign travel and credit transactions. And Epstein himself provides the answer to the “but there are several kinds of IDs” argument: require a state drivers license, US Passport, or US Military ID. Those are harder to forge and narrows the training requirement.

  13. jwest says:

    Just a little food for thought about voter fraud.

    – Missouri, according to a comparison of its Secretary of State voter statistics with its US Census statistics, shows fifteen counties with more than 100 percent voter registration:
    Reynolds County, 125.8 percent
    Putnam County, 109.9 percent
    Butler County, 104.3 percent
    Gentry County, 103.9 percent
    Mercer County, 103.6 percent
    Shelby County, 103.2 percent
    Schuyler County, 101.6 percent
    Carter County, 101.5 percent
    Worth County, 101.4 percent
    Ozark County, 100.8 percent
    Dade County, 100.7 percent
    Holt County, 100.6 percent
    Pemiscot County, 100.6 percent
    Howard County, 100.4 percent
    Ralls County, 100.1 percent

    Fifteen Missouri counties have more voters than census population
    Missouri Watchdog.org
    October 26, 2010

    Missouri has about 90.3 percent of its census voting-age population registered to vote, but 15 counties show more registered voters than people 18 and older.

    Missouri counties with more than 100 percent voter registration •
    Reynolds County, 125.8 percent
    • Putnam County, 109.9 percent
    • Butler County, 104.3 percent
    • Gentry County, 103.9 percent
    • Mercer County, 103.6 percent
    • Shelby County, 103.2 percent
    • Schuyler County, 101.6 percent
    • Carter County, 101.5 percent
    • Worth County, 101.4 percent
    • Ozark County, 100.8 percent
    • Dade County, 100.7 percent
    • Holt County, 100.6 percent
    • Pemiscot County, 100.6 percent
    • Howard County, 100.4 percent
    • Ralls County, 100.1 percent

  14. PD Shaw says:

    jwest, the main thing I think of with that Missouri list, is that (a) they all appear to be “Republican” counties, and (b) they all appear to be sparsely populated. (Reynolds County has 6,000 residents) I’m not sure what that means, but it’s interesting.

  15. Gustopher says:

    It’s also worth noting that ACORN was legally required to submit all of the Voter Registration Forms collected, even if they had reason to be suspicious of them.

  16. Rick Almeida says:

    Indeed, from that very article you quoted (and I link here:

    Often, inactive voters appear on the list because the local election authority is waiting the required two federal election cycles before the voter can be removed. The decision in the Department of Justice case you referenced states that federal law “makes it inevitable that voter registration lists will be inflated” because of its requirement that local election authorities wait to remove a voter who has not responded to a canvass mailing until they fail to vote in two successive federal elections.

  17. It is amazing how strenuous the objections are to a remarkably minor inconvenience meant to help safeguard the sanctity of our votes.

    Shocking, really.

  18. mantis says:

    – Missouri, according to a comparison of its Secretary of State voter statistics with its US Census statistics, shows fifteen counties with more than 100 percent voter registration:

    From the website you reference:

    [Update] Laura Egerdal, spokesperson for the Missouri Secretary of State, gave this response on Wednesday:

    I would encourage you to take a closer look at the number of active voters, rather than total registered voters. Often, inactive voters appear on the list because the local election authority is waiting the required two federal election cycles before the voter can be removed. The decision in the Department of Justice case you referenced states that federal law “makes it inevitable that voter registration lists will be inflated” because of its requirement that local election authorities wait to remove a voter who has not responded to a canvass mailing until they fail to vote in two successive federal elections.

    Missouri’s voter registration rolls are more accurate than ever before, thanks to the diligent work of local election authorities. Over the past 5 years, our office has actively monitored the list maintenance activities of the local election authorities, issued regular reminders on the requirements of state and federal law, and conducted dozens of trainings across the state. Resources such as state vital records information from the Department of Health and Senior Services (identifying deceased voters in Missouri) are updated at least weekly, and we’ve regularly performed matches with the Social Security Administration death records database.

    No wonder you didn’t bother to include a link. It would show your claims to be baseless.

  19. PJ says:

    I’m not sure what that means, but it’s interesting.

    Jwest, or rather Missouri Watchdog, has obviously uncovered a massive voter fraud scheme perpetrated by Missouri Republicans…

    😉

  20. mantis says:

    It is amazing how strenuous the objections are to a remarkably minor inconvenience institution of illegal poll taxes meant to help safeguard the sanctity of our votes prevent certain portions of the population from voting.

    Fixed that for you.

  21. ALP says:

    I agree with you James, but let me make some points.
    1. I don’t know how much actual voter fraud really occurs,
    but I believe there is some.

    2. Even the disabled, if they can go out to vote, they can
    surely get a State Photo I.D. If they cannot get out of
    their house and vote, then a family member or caretaker
    could register for an absentee ballot for them, but only
    in person, at a registration center along with their
    Photo I.D.

    3. All other applications for absentee ballots must be
    registered in person before voting, except military on
    active duty or deployed.

    4. Civilians living or working out of country can
    register before they leave. if they are gone for more than
    4 years without returning, then they don’t get to vote.
    After all they probably don,t pay taxes to the U.S.

    5. This idea of someone not directly associated with
    another person registering them to vote is wrong, and
    could lead to voter fraud.

    Now I am sure that many of you TLs’ (Totalitarian Liberals) out
    there are going to jump all over my A** and spout a lot of
    lame excuses about how some of if this is just too hard
    for some people to do. If they cannot accomplish these
    simple tasks, then they should not vote!

  22. Tano says:

    I don’t know how much actual voter fraud really occurs,
    but I believe there is some.

    Why do you believe that? Is this purely a faith-based conclusion? Is it that you figure that if all conservatives repeat this endlessly, then there must be some truth to it?

  23. Tsar Nicholas says:

    Ask Woody Jenkins or Dino Rossi or Richard Nixon whether a photo I.D. to vote should be required…

  24. Having an ID is a poll tax? Really?

    And stop projecting your nefarious fantasies on to me please. Thank you. I don’t wish to deprive anyone of the right to vote, but you seem awfully damn sensitive to attempts to limit fraud. Why is that?

  25. Fog says:

    Let’s see…
    There is no significant voter fraud problem in this country, but somebody wants to fix what ain’t broke. Why is that?

  26. Dave Schuler says:

    This is completely anecdotal but in nearly a quarter century of working as an election judge in only one election (1992) did I see anything that I suspected was vote fraud. In that particular election we had received instructions from the Board of Elections on handling non-registered voters that we followed to the letter. We had a flood of “voters” who were not registered, who almost certainly did not live in the precinct, and whom I suspected were ineligible but, according to the instructions we’d received, we allowed them to vote anyway. The instructions were tightened substantially in the next election.

    If my experience is any gauge vote fraud is actually quite rare. However, based on my observation of the procedures and what I’ve seen in other precincts I suspect that election fraud is actually pretty common if only by inadvertence. Few election judges really understand the procedures, fewer follow them, and if there’s advertent fraud going on the election judges are in the best position to perpetrate it.

  27. fog, since you are going to qualify it, I’ll note that we apparently have different concepts of what constitutes significant. One instance is too many.

  28. Richard Gardner says:

    John Fund at the Wall Street Journal has been covering the voter fraud beat for quite awhile, he even wrote a book about it. So it isn’t just the scapegoat of Fox News. Here is an article he wrote about Milwaukee WI.

    I believe the vote-by-mail systems in some states are much more prone to fraud. All it takes is some right-wing mailman to toss out the ballots in a liberal area, or vice-versa. Plus some states do not have a good method to eliminate dead/ineligible voters from the rolls.

    In the case of Dino Rossi in 2004 (WA State governor’s race vs. Gregoire), myriad systemic issues were uncovered in the registration and voting process, but there was no evidence of an organized effort to commit vote fraud (except perhaps one Alzheimer’s facility north of Seattle). Instead there was sheer incompetence (and underfunding/under-staffing) in the Auditor’s offices, particularly in strongly-Democratic Party leaning King County (Seattle), though issues were found across the state. The folks at Sound Politics (Sharkansky) found more ineligible voters voted than the race was decided on (on the 3rd recount), but there was no way to reverse those votes.

    BTW, the man who headed the awful voter office in King County, WA was allowed to resign (otherwise he would have been fired) and is now in charge of Los Angeles County’s voter system.

  29. mantis says:

    Having an ID is a poll tax?

    Requiring citizens to pay for something (an ID) to vote is indeed a poll tax. If the state were to decide to give them away for free, then there would be no problem.

    Really?

    Yes, really.

    And stop projecting your nefarious fantasies on to me please. Thank you. I don’t wish to deprive anyone of the right to vote,

    Fine, then you’ve been duped by those who do.

    but you seem awfully damn sensitive to attempts to limit fraud. Why is that?

    Because these attempts are there to discourage people to vote, not to limit fraud that doesn’t exist. The fraud isn’t happening, as was the point of this post.

  30. mantis says:

    John Fund at the Wall Street Journal has been covering the voter fraud beat for quite awhile, he even wrote a book about it. So it isn’t just the scapegoat of Fox News

    Fox News and WSJ are part of the same company.

  31. Richard Gardner says:

    Fox News and WSJ are part of the same company.

    The weren’t back when he wrote the book, nor at the date of the article I linked.

  32. mantis says:

    The weren’t back when he wrote the book, nor at the date of the article I linked.

    Not when he wrote his ridiculous book, no, but the WSJ most certainly was part of News Corp when he wrote the article you linked.

  33. Scott says:

    Richard, I live in Oregon, all votes here are by mail. It’s announced in the news when ballots are going out and later we’re told that if you haven’t received your ballot yet call your local registrar so I’m sure a mail man could not do what John Fund suggests.

    I can envision unwanted scenarios like Dad “helping” the family fill out their ballots but in the 12 years we’ve had it I haven’t heard of any serious problems.

  34. steve says:

    Again, many people are convinced that there is voter fraud occurring, but there are almost no cases of voter fraud being prosecuted. Either the people committing the fraud are incredibly clever, the people looking for them incredibly dumb or there just isnt much fraud. I dont get that many days off. Please explain to me why I should take one of those days to get a photo ID for a problem that does not exist. I fit exists, prove it.

    Steve

  35. Hal Hildebrand says:

    As the saying goes, it’s hard to prove a negative, which is why the assertions that it exists by the right.

  36. Fog says:

    Charles:
    So we’re going to overhaul a system that works rather well to try to eliminate potential for fraud? Unfortunately, no voting system can be 100% fraud-proof, so you’re asking us to spend a lot of time and money for an incremental decrease in the potential for fraud when there’s no evidence of a fraud problem in the first place. I’d call that wasteful, and so obviously wasteful that I can thoroughly understand someone thinking that there are ulterior motives at work.
    As long we still use hackable computerized voting machines anywhere in this country, I can’t get too wound up about voter ID laws.

  37. Hal Hildebrand says:

    Obviously, it isn’t about voter fraud. It’s telling that only one party obsesses about it, and goes to amazing lengths to create the functional equivalent of a poll tax which will fall disproportionately on those that vote against them.

    It’s rather simple.

  38. jwest says:

    “I live in Oregon, all votes here are by mail.”

    This is one of the things that must be stopped. Voting by mail is an invitation to fraud.

    Union thugs will demonstrate their “civic duty” by “suggesting” that all members who want to be eligible for overtime or good assignments bring their ballots down to the union hall, where their helpful officials will insure each ballot is filled out “properly”.

    How can anyone who values the premise of a secret ballot possibly be for voting by mail?

  39. steve says:

    “Union thugs will demonstrate their “civic duty” by “suggesting” that all members who want to be eligible for overtime or good assignments”

    Where has this happened?

    Steve

  40. wr says:

    jwest — The most basic assumption of any democracy is that the people are capable of making their own decisions. You have decided that they are not, and therefore can not be trusted to cast votes without your supervision. (Not unlike your belief that African Americans are too dumb to make it in America, and therefore were better off as slaves.)

    People are allowed to make their electoral choices on any basis they desire. If they want to go down to the union hall and be told who to vote for, they can. If they want to listen to the corporate shills on Fox and be told who to vote for, that’s their right, too.

    If there is ever a single count of coerced voting like the one you fantasize about, it will be prosecuted as a felony. But just because you are capable of dreaming up some ridiculous scenario is not actually a reason to force an entire state to change the way it votes. Even if they do elect Democrats.

  41. Scott says:

    jjwest, what you’re describing isn’t necessary in this state. If Republicans start to become a majority in any county the unionized cops do some culling.

  42. Brett #2 says:

    As an intuitive matter, I’m flummoxed by the idea that being required to possess and show voter identification is either burdensome or somehow particularly intimidating to members of racial minority groups.

    If we had some form of cheap picture ID that was accepted at elections and didn’t involve getting either a Drivers’ License or Passport, I’d be on board with that.

    As is, that’s frequently not the case – and Republicans aren’t helping. In either Wisconsin or New Hampshire (one of the two), the Republican-dominated state legislature wanted to repeal Same-Day Registration and forbid the usage of Student IDs as valid at election sites.

  43. Raoul says:

    Virginia does not require photo ID to vote!

  44. John Burgess says:

    @ALP: Your items #3 and #4 might need some tweaking:

    3. All other applications for absentee ballots must be
    registered in person before voting, except military on
    active duty or deployed.

    4. Civilians living or working out of country can
    register before they leave. if they are gone for more than
    4 years without returning, then they don’t get to vote.
    After all they probably don,t pay taxes to the U.S.

    I was a US Foreign Service Officer living abroad for stretches of up to 11 years. As a civilian, I’d have lost my right to vote under your layout. Doesn’t at all work for me.

    Florida does require a photo ID in order to vote. Further, there is no charge for a simple, state-issued photo ID, in lieu of some other photo ID (e.g. driver’s license) for which charges are made. This isn’t a poll tax. Florida also excludes most ex-felons, excepting those who have successfully petitioned for a return of their rights.

  45. wr says:

    John Burgess — Florida also used to exclude most people whose names were somewhat similar to those of ex-felons, as long as they were black. One more reason W “won” the state in 2000…

  46. PJ says:

    Charles Austion on

    I’ll note that we apparently have different concepts of what constitutes significant. One instance is too many.

    And here I thought that you thought that “the perfect is the enemy of the good”?

    So while one instance of voting fraud is one too many, one instance of someone innocent being put to death, not so much?

  47. anjin-san says:

    > Now, people have irrational fears

    Well, if you are gullible, and you have seen that video of black voters standing in line at a precinct with a blaring headline about voter fraud that Fox has shown about a million times, maybe it seems like a rational fear…

  48. jwest says:
  49. Scott says:

    “GOP says”

    Not much more needs to be read.

  50. Scott says:

    Here’s the actual report

    http://cha.house.gov/images/stories/documents/co_non_citizen_report.pdf

    In it you’ll find this early on, “the Department of State is nearly certain that 106 individuals are improperly registered to vote.”

  51. Hal Hildebrand says:

    I think the percentage of allowed fecal matter in food is actually higher than this percentage.

    Top marks!

  52. jwest says:

    “the Department of State is nearly certain that 106 individuals are improperly registered to vote.”

    For those who didn’t go to the link provided by Scott, here is what it actually says:

    “ The comparison identified 11,805 individuals who (1) were non-citizens at the time they obtained a driver’s license, and (2) are registered to vote. As discussed below, the Department of State is nearly certain that 106 individuals are improperly registered to vote. And potentially many of the remaining 11,805 individuals are also improperly registered to vote. It is impossible to provide a precise number, however, because voter registration data are inconclusive.”

    Almost 12,000 non-citizens registered to vote in Colorado. How many do you think there are in California?

  53. Scott says:

    In California I am nearly certain that potentially there are many. We would need to examine each resident’s original long form birth certificate.