The Seventh Circuit Court of Appeals ruled on August 19, 2026, in the case of Public Interest Legal Foundation, Inc. v. Meagan Wolfe, affirming a lower court's decision that Wisconsin's voter registration exemption is valid. The ruling affects organizations seeking access to voter registration records in states that have same-day voter registration, like Wisconsin, and clarifies the application of the National Voter Registration Act (NVRA).
The Public Interest Legal Foundation (PILF), a nonprofit organization focused on election integrity, filed a lawsuit against Meagan Wolfe, the Administrator of the Wisconsin Elections Commission, after the commission denied its request for the state's voter registration list. The foundation argued that Wisconsin's exemption from the NVRA violated principles of equal state sovereignty and the congruence and proportionality test under the Fourteenth Amendment. The case was filed under docket number 24-3258.
The dispute arose when PILF requested the voter registration list in January 2024, citing the NVRA, which mandates that states provide access to voter registration records. However, Wisconsin is exempt from this requirement due to its same-day polling-place registration law, which has been in place since August 1, 1994. The Wisconsin Elections Commission informed PILF that it would process the request under state public records law, which includes redactions for sensitive information like voters' birth dates and a fee that could reach up to $12,500 for the extensive list.
PILF objected to both the fee and the redaction of information, leading to the lawsuit. The foundation's primary claim was that the NVRA's exemption for Wisconsin violated the equal sovereignty principle established in the 2013 Supreme Court case Shelby County v. Holder. It also argued that the exemption did not meet the congruence and proportionality requirement set forth in City of Boerne v. Flores, a 1997 case concerning Congress's power to enforce the Fourteenth Amendment.
The district court dismissed PILF's case, agreeing with the Wisconsin Elections Commission that the NVRA's exemption was valid. The court noted that the exemption relieved Wisconsin from federal regulatory burdens, contrasting it with the preclearance requirement invalidated in Shelby County, which placed additional burdens on certain states.
In its ruling, the Seventh Circuit, led by Judge Sykes, stated, "The exemption at issue here does exactly the opposite: It relieves Wisconsin from federal regulatory burdens because its voter-registration laws already align with federal policy." The court emphasized that the NVRA's exemption serves to recognize states that have consistently aligned their voter registration practices with federal standards.
The ruling also addressed PILF's standing to sue, concluding that the foundation's claims did not sufficiently demonstrate a violation of its own rights, as it was attempting to assert the rights of the state of Wisconsin. The court noted that the foundation's arguments did not establish a direct injury that warranted federal court intervention.
The implications of this ruling are significant for organizations seeking access to voter registration data in states with similar exemptions. It reinforces the authority of states to regulate their own voter registration processes without federal interference, particularly for states that have demonstrated compliance with federal standards for voter registration.
Going forward, this decision may discourage similar lawsuits by organizations attempting to challenge state exemptions from federal voting laws. It also highlights the ongoing debate surrounding voter access and election integrity, especially in the context of varying state laws.
As for what’s next, PILF could potentially appeal the ruling to the Supreme Court, although it remains unclear if the high court would take up the case. There are no related cases pending that directly address this issue, but the ruling may influence future litigation involving voter registration access and state sovereignty.