Complaint:

1. This action seeks declaratory and injunctive relief to stop an administrative policy employed by the Georgia Secretary of State that creates an illegal precondition to voter registration and, if not enjoined, will unlawfully disenfranchise tens of thousands of Georgia voting-eligible citizens, the vast majority of whom are minorities, in the November 2016 election and thereafter.
2. Under the Georgia Secretary of State’s current administrative policy, voter registration applications submitted by eligible voters are not added to the list of persons eligible to vote if certain identifying information does not match exactly with existing Georgia Department of Driver Services or Social Security Administration records. Voter registration applicants whose information does not match those records are not allowed to cast a valid ballot unless they overcome a series of burdensome bureaucratic hurdles that deprive them of their fundamental right to vote, unless they happen to fall within a couple of narrow and arbitrary exceptions. Those who cannot overcome these hurdles are denied the right to vote.
3.  Insistence on digit-by-digit and character-by-character exactitude when comparing information from one database with information in a different database is a notoriously unreliable method of verification in the elections context. The “match” process is invariably plagued with errors, especially when the match criteria demand an exact match across numerous data fields. Mismatches between databases can result from innocuous mistakes such as omitting a hyphen or initial, and frequently result from no fault of the voter whatsoever. Examples include data entry errors, typos, misreading of imperfect 3 handwriting by elections officials and computer glitches within the State’s registration system. None of these common errors relate to a voter’s eligibility to vote, yet may routinely result in disenfranchisement under the Secretary’s policy.
4.  There are many ways in which the records of eligible voters who submit truthful and accurate registration applications will fail to “match.” For example, voters who register in their married names will not match if their driver’s license or Social Security records are in their maiden names. Voters with compound last names will not be deemed a match if one database assigns part of the last name to the middle name position, but the other does not. Voters with symbols in their name, such as accent marks, will not match if one database recognizes those symbols and another does not. Finally, the voter’s records will not be deemed a match if the person doing the data entry omits or transposes any digits or characters when entering information from a voter registration

More in the press release.