Case Explained: 26a0180p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-24 The sixth-circuit affirmed the district court’s dismissal of the United States’ lawsuit seeking to compel Michigan Secretary of State Jocelyn Benson to produce an unredacted statewide voter registration list under Title III of the Civil Rights Act of 1960. The court held that the statute does not authorize the government to demand the “qualified voter file” because the phrase “come into [her] possession” in 52 U.S.C. § 20701 requires election officers to acquire, obtain, or receive records from a third party, whereas Michigan’s voter file is an internally generated database created and maintained by state officials. The court further reasoned that interpreting the statute to cover self-generated compilations would create a conflict with the National Voter Registration Act (NVRA) and the Help America Vote Act (HAVA), which require officials to routinely update and alter these lists, whereas Title III criminalizes the willful alteration of records it mandates be preserved. Additionally, the court ruled that the government failed to comply with the mandatory procedural requirements of 52 U.S.C. § 20703, which requires a written demand to contain both a statement of the “basis” and the “purpose” for the inspection; the government’s correspondence either cited the wrong statutory authority or failed to provide both required elements in a single demand. As a result, the dismissal of the complaint was upheld, leaving the Secretary of State under no obligation to provide the unredacted voter data sought by the federal government. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.