Danielle Lang

Around Election Day in 2018, after the Supreme Court had allowed North Dakota to enforce a voter-identification law that required a current residential address, Lang and her colleagues spent about two weeks driving across the state, from Standing Rock on its southern border to Spirit Lake and on to Turtle Mountain on its northern one. At his kitchen table on the Spirit Lake Reservation, Dion Jackson held his baby and showed her the letter rejecting his application for an absentee ballot. The address on the application, the same one printed on his North Dakota identification card, had been rejected as invalid. He had never voted; a political event on the reservation had made him want to, and he took the letter to mean he could not.

He became one of six tribal members who joined the Spirit Lake Nation in suing Secretary of State Al Jaeger, and the next morning a news van was in front of his house. A court order allowed him and his fellow plaintiffs to vote.

On one road Lang found five names for the same street: one on Google Maps on her phone, another on Bing, a third on her client’s state-issued identification, a fourth in the state’s official GPS system and a fifth on a nearby street sign. Nearly everyone she met on the reservations received utility bills, bank statements and ordinary mail at post-office boxes, and until recently many state and tribal IDs had carried those box numbers. The suit blamed the state’s system for assigning addresses on reservations; more than 250 people, it said, had no street address assigned to their homes.

In Spirit Lake Tribe v. Jaeger, Lang helped lead the Campaign Legal Center team that, with the Native American Rights Fund, represented the Spirit Lake Nation, the Standing Rock Sioux Tribe, which later joined the case, and individual voters. Judge Daniel Hovland rejected the state’s request to dismiss, and the case was set for trial in May 2020. After a mediation at the state capitol on February 6, 2020, the parties reached an agreement in principle, and on April 24 they filed a binding agreement to take effect before the June 9 primary. North Dakota would accept tribal identification and tribally designated addresses. A voter who lacked or did not know a residential address could locate the home on a map, at the polls or when applying for an absentee ballot; county officials would supply the address, and the ballot would be counted.

The state also agreed to bring the Department of Transportation to every reservation to issue nondriver identification free of charge within thirty days of each statewide election, to seek reimbursement of the tribes’ costs of producing IDs, and to provide public education and poll-worker training on the new procedures, with measures for the tribes to monitor compliance. CLC counted more than 7,000 residents of the two nations among those who would benefit.

Restore Your Vote

In 2018 Lang and Blair Bowie founded CLC’s Restore Your Vote project, which helps people with past convictions work through each state’s rules for restoring the right to vote, including people who do not know they are already eligible. She had come to voting rights from employment law. After graduating with honors from New York University in 2008 and from Yale Law School in 2012, she clerked for Judge Richard A. Paez of the United States Court of Appeals for the Ninth Circuit and then, as a Skadden Fellow in the Employment Rights Project at Bet Tzedek Legal Services in Los Angeles, represented low-wage immigrant workers in wage-and-hour, discrimination and human-trafficking cases. She joined the Campaign Legal Center in 2015. At Georgetown University Law Center she co-teaches the Election Law Practicum with Jonathan Diaz as an adjunct professor.

Citizens Caught in Registration Lists

In January 2019 the Texas secretary of state’s office said that as many as 95,000 registered voters matched Department of Public Safety records identifying them as noncitizens, and advised counties to investigate them. The list was largely made up of naturalized citizens, among them Julie Hilberg, who sued with LULAC, the League of United Latin American Citizens; CLC represented both. On February 27, 2019, Judge Fred Biery of the federal court in San Antonio ordered the state to tell counties to halt the removals and barred it from sending notice-of-examination letters or removing voters “without prior approval of the Court.” Lang, then co-director of CLC’s voting rights and redistricting program, called the ruling “a major victory for Texas voters.” In April the state settled: it rescinded its advisory, ended the program and agreed that naturalized citizens would not again be targeted for removal on the basis of old license data.

In Alabama the list came eighty-four days before the 2024 general election. On August 13, 2024, Secretary of State Wes Allen announced that 3,251 registered voters who had once been issued noncitizen identification numbers would be made inactive and referred to the attorney general for criminal investigation. CLC, with the Southern Poverty Law Center, the Fair Elections Center and local counsel, sued for four Alabama voters, the Alabama Coalition for Immigrant Justice, the League of Women Voters of Alabama and the Alabama NAACP. The National Voter Registration Act bars systematic removals within ninety days of a federal election, and Allen’s chief of staff testified that about 2,000 of the 3,251 were registered citizens.

On October 16, 2024, Judge Anna M. Manasco, who said the office “blew the deadline for the 2024 general election,” entered a preliminary injunction. Within three days Allen had to tell county registrars to reactivate affected voters who had not died, been disqualified or asked to be removed, supply remedial mailers and post the order; within five days he had to tell the attorney general’s office that some referred voters had been misidentified. The order restored American-born and naturalized citizens alike. By March 2025 the state had abandoned the program, and the plaintiffs dismissed their case.

The President and the Federal Forms

In March 2025 the President issued an executive order directing the Election Assistance Commission to require documentary proof of citizenship on the national mail voter-registration form. Lang’s CLC team and Democracy Defenders Fund sued for LULAC, Secure Families Initiative and the Arizona Students’ Association, arguing that the Constitution gives the power to regulate elections to the states and Congress.

On October 31, 2025, Judge Colleen Kollar-Kotelly granted partial summary judgment and permanently barred the commission from adding the requirement to the federal form because, she wrote, “our Constitution assigns responsibility for election regulation to the States and to Congress.” On January 30, 2026, she permanently blocked two more provisions: agencies may not assess citizenship before offering the federal form to people enrolling in public-assistance programs, and the Secretary of Defense may not require documentary proof of citizenship when service members register or request ballots. The Constitution, she wrote, “does not allow the President to impose unilateral changes to federal election procedures.” The second ruling, Lang said, “removes a very real threat to the freedom to vote for overseas military families.”

Mail Ballots and the Election Calendar

A second executive order, signed March 31, 2026, directed the Postal Service to write a rule for mail-ballot envelopes carrying a unique barcode and required states to tell the Postal Service ninety days before an election whether they would allow mail voting and to submit lists of mail voters sixty days before. At a May 14 hearing before Judge Carl J. Nichols, Lang, arguing for LULAC, said the order seemed designed to create the “maximum amount of chaos and confusion” in elections: the final rules would arrive after some primaries and before others, leaving voters and election officials sixty days to adjust.

The Postal Service then issued its final rule, with a Federal Ballot Mail Portal, participant lists and a verification requirement for outbound ballots. In support of LULAC’s renewed motion, Lang’s team offered the declaration of Tammy Patrick, an election-administration expert. North Carolina, she noted, would begin mailing ballots on September 4, and “Redesigning and reordering envelopes for any reason is not feasible,” work ordinarily done “in odd-numbered years, off cycle from federal elections.” On September 13, 2026, Judge Nichols, describing Patrick’s evidence on envelope redesign, portal delays and verification delays as “essentially uncontested,” granted the motion and held that the portal, participant-list and verification provisions likely exceeded the Postal Service’s statutory authority. Nine days earlier, Judge Indira Talwani in Boston had blocked the rule in a separate case in which CLC filed an amicus brief, and on September 14 the Supreme Court left her injunction in place.

In Watson v. Republican National Committee, CLC and Protect Democracy filed an amicus brief arguing that Congress, had it wanted to change ballot-receipt deadlines, could have done so in the Electoral Count Reform Act of 2022. On June 29, 2026, the Supreme Court held, in an opinion by Justice Amy Coney Barrett, that the federal election-day statutes do not bar Mississippi from counting absentee ballots postmarked by Election Day and received up to five business days later; roughly thirty states count such ballots. “All voters, no matter how they cast their ballot, deserve the freedom to make their voices heard,” Lang said. “This is a cornerstone of American democracy.”

Two Registration Forms

Arizona registers voters on two forms, its own and the federal one, which requires a sworn statement of citizenship but no document proving it. In November 2017 Lang and her CLC colleagues, with the Lawyers’ Committee for Civil Rights Under Law, sued Secretary of State Michele Reagan and Maricopa County Recorder Adrian Fontes for LULAC Arizona and the Arizona Students’ Association, alleging that the dual system may have disenfranchised roughly 26,000 voters in Maricopa County alone. On June 18, 2018, Judge David G. Campbell approved a consent decree: officials would accept state-form applications submitted without documentary proof of citizenship, register those applicants for federal elections and check their citizenship against the motor-vehicle database.

In 2022 Arizona enacted H.B. 2492, requiring officials to reject state-form applications submitted without documentary proof of citizenship, and H.B. 2243, requiring monthly checks for suspected noncitizens and cancellation of their registrations. Judge Susan Bolton held that both laws violated the National Voter Registration Act and that the proof requirement violated the 2018 consent decree, and in February 2025 the Ninth Circuit upheld those rulings, holding as well that the act forbids systematic cancellations within ninety days of a federal election.

On June 29, 2026, the day it decided Watson, the Supreme Court agreed to hear the Republican National Committee’s appeal. Lang is counsel of record for respondent groups, among them Living United for Change in Arizona, LULAC Arizona, the Arizona Students’ Association, the Inter Tribal Council of Arizona and the San Carlos Apache Tribe, in the companion petitions filed by Arizona’s legislative leaders and by the state. The questions presented are whether the National Voter Registration Act or the 2018 consent decree bars Arizona from requiring documentary proof of citizenship on its own form, and whether the act bars cancelling suspected noncitizens’ registrations within ninety days of a federal election. The Court set the case for argument on December 8, 2026.