NC law removing voters for undeliverable mail does not violate voting rights, federal court rules ...Middle East

Sydney Meeks, NextGen regional organizing director, and Logan Parke, Chapel Hill field organizer, talk to a UNC-CH student during a National Voter Registration Day campus visit. (Photo by Lynn Bonner/NC Newsline)

A federal judge upheld a 2023 North Carolina law allowing voter registrations to be denied after just one address verification card is returned as undeliverable, marking a second victory for the General Assembly’s ballot restrictions in just one day.

Previously, voters would receive two mailed address verification requests from the State Board of Elections before their registration would be denied and their ballot canceled. The provision was blocked from going into effect for the 2024 election by U.S. District Judge Thomas Schroeder, who ultimately upheld the law Thursday, and so it will first apply to the upcoming 2026 election.

A trio of civil rights groups — Democracy North Carolina, the North Carolina Black Alliance, and the League of Women Voters of North Carolina — challenged the law, known as Senate Bill 747, in 2023, a week after it passed over Gov. Roy Cooper’s veto.

The three organizations, represented by the Southern Coalition for Social Justice, argued that the law discriminates against young voters, and students in particular, by making it easier to discard their votes. The case went to trial in October 2025.

Because many young voters cast ballots away from home while studying at college and move more frequently than older voters, the groups argued, they are significantly more likely to miss a single mailed verification request. Expert testimony provided at the trial showed that over the last 15 years, young voters have disproportionately relied on the second request to verify their registration, with around 20,000 confirming their eligibility to vote this way.

Schroeder, a judge in the Middle District of North Carolina, ruled that the civil rights groups failed to demonstrate that the legislature passed S.B. 747 with intent to discriminate against any group of voters, the same grounds under which the Middle District struck down a challenge to the state’s photo voter ID law on Thursday.

Recent rulings from the U.S. Supreme Court and the 4th Circuit Court of Appeals have significantly raised the threshold to establish voting rights violations. A successful challenge must show clear intent by lawmakers to discriminate against a group of voters and demonstrate an unreasonable burden placed on voters at large, not only that group.

Schroeder said lawmakers had legitimate reason for election integrity concerns. Some voters who completed same-day registrations had their ballots counted under the previous law, he said, even though both cards were eventually returned as undeliverable. In those cases, the votes could not be challenged in time because the second undeliverable notice made it back only after the county canvass.

“A legislature is entitled to make such policy choices and is not precluded from improving its electoral system because of its inability to perfect it,” Schroeder wrote. “Nor should election changes become a one-way ratchet, incapable of alteration merely because some voters may be affected.”

He also noted that the State Board of Elections sends a “Notice to Verify Your Address” by mail and email if the county board receives the undeliverable verification card at least two days before the election canvass, providing voters a second opportunity to cure their ballots.

“Any burden on voting rights from SB 747 with its notice-and-cure provisions is minimal, at best, given North Carolina’s array of methods to register and vote,” Schroeder wrote. “And such minimal burden is justified in relation to the State’s legitimate interests in preventing voter fraud, promoting election integrity, addressing the appearance of voter fraud, and ensuring efficient election administration.”

Adrianne Spoto, voting rights counsel for the Southern Coalition for Social Justice, said the ruling will have “devastating consequences for our electoral system for decades to come.”

“When young voters casting their first ballots see them rejected for technical snafus, it creates lasting barriers to participation and jeopardizes their lifelong civic engagement,” Spoto said.

Democracy NC executive director Adrienne Kelly said the law was an effort by the legislature to “attack our state’s incredible student voter bloc.”

“Today’s deeply disappointing decision is sadly no surprise given these systemic efforts to silence young voices, particularly from communities of color, by any means necessary,” Kelly said.

Sam Hayes, the executive director of the North Carolina Board of Elections, said in a statement that both of the decisions Thursday vindicate the state’s election protection efforts.

“This decision affirms that same-day registration safeguards are constitutional and serve an important role in ensuring that registrants are who they say they are,” Hayes said of the decision in the Democracy NC case. “We are pleased with the court’s ruling and appreciate its thorough review of this matter.”

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