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Low turnout also occurs when some citizens are not allowed to vote. One method of limiting voter access is the requirement to show identification at polling places. In 2005, the Indiana legislature passed the first strict photo identification law. Voters must provide photo identification that shows their names match the voter registration records, clearly displays an expiration date, is current or has expired only since the last general election, and was issued by the state of Indiana or the U.S. government. Student identification cards that meet the standards and are from an Indiana state school are allowed.

“Photo ID Law,” http://www.in.gov/sos/elections/2401.htm (November 1, 2015).
Indiana’s law allows voters without an acceptable identification to obtain a free state identification card.
“Obtaining a Photo ID,” http://www.in.gov/sos/elections/2625.htm (November 1, 2015).
The state also extended service hours for state offices that issue identification in the days leading up to elections.
“Media Information Guide for Indiana 2014 General Election,” http://www.state.in.us/sos/elections/files/2014_General_Election_Media_Guide_with_Attachments_11.03.2014.pdf (November 13, 2015).

The photo identification law was quickly contested. The American Civil Liberties Union and other groups argued that it placed an unfair burden on people who were poor, older, or had limited finances, while the state argued that it would prevent fraud. In Crawford v. Marion County Election Board (2008), the Supreme Court decided that Indiana’s voter identification requirement was constitutional, although the decision left open the possibility that another case might meet the burden of proof required to overturn the law.

David Stout, “Supreme Court Upholds Voter Identification Law in Indiana,” New York Times , 29 April 2008; Crawford v. Marion County Election Board , 553 U.S. 181 (2008).

In 2011, Texas passed a strict photo identification law for voters, allowing concealed-handgun permits as identification but not student identification. The Texas law was blocked by the Obama administration before it could be implemented, because Texas was on the Voting Rights Act’s preclearance list. Other states, such as Alabama, Alaska, Arizona, Georgia, and Virginia similarly had laws and districting changes blocked.

“Jurisdictions Previously Covered by Section 5,” http://www.justice.gov/crt/jurisdictions-previously-covered-section-5 (November 1, 2015).
As a result, Shelby County, Alabama, and several other states sued the U.S. attorney general, arguing the Voting Rights Act’s preclearance list was unconstitutional and that the formula that determined whether states had violated the VRA was outdated. In Shelby County v. Holder (2013), the Supreme Court agreed. In a 5–4 decision, the justices in the majority said the formula for placing states on the VRA preclearance list was outdated and reached into the states’ authority to oversee elections.
Shelby County v. Holder , 570 U.S. ___ (2013).
States and counties on the preclearance list were released, and Congress was told to design new guidelines for placing states on the list.

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Source:  OpenStax, American government. OpenStax CNX. Dec 05, 2016 Download for free at http://cnx.org/content/col11995/1.15
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