677 F.3d 383 (9th Cir. 2012)
The case of Gonzalez v. Arizona is pivotal in understanding the intersection of state and federal power in the regulation of voting requirements.
Does Arizona's voter ID law requiring proof of citizenship at registration conflict with the National Voter Registration Act, thereby being pre-empted by federal law?
The National Voter Registration Act requires states to 'accept and use' the federal voter registration form, which does not require documentary proof of citizenship. States may not impose additional requirements inconsistent with the NVRA.
The Ninth Circuit held that Arizona's proof of citizenship requirement for voter registration was pre-empted by the NVRA, but the identification requirement at the polls was not.
Gonzalez v. Arizona is critical for law students as it highlights the nuances of federalism in United States election laws. It showcases how federal laws can preempt state laws, especially in areas constitutionally reserved to states. The decision also offers insight into how courts balance state interests in maintaining electoral integrity against federal objectives of maximizing voter access.