Arizona v. Inter Tribal Council of Arizona (2013)
Arizona voters passed Proposition 200 in 2004, requiring documentary proof of citizenship to register. Voting rights groups sued, and the case reached the Supreme Court. Justice Antonin Scalia, writing for a 7-2 majority, ruled that federal law preempted Arizona's requirement because the National Voter Registration Act mandates states accept the federal registration form, which requires only an attestation of citizenship.
Arizona could not require citizenship documentation for voters using the federal form, though it maintained a separate state-only registration with stricter requirements.
The decision established that Congress, not states, controls federal voter registration standards—the same constitutional framework the SAVE America Act would now use in reverse to impose federal mandates on states.
The SAVE America Act attempts to do through Congress what Arizona tried to do through state law: require documentary proof of citizenship. If passed, it would effectively overturn the practical effect of this ruling by changing federal law itself.