Last Updated September 2025
August 29, 2025: Kohls v. Bonta
On August 29, a Federal District Court issued a permanent injunction preventing the California Secretary of State and Attorney General from enforcing Assembly Bill (AB) 2839 against the plaintiffs. AB 2839 was enacted by the California Legislature to combat the spread of materially deceptive deepfake election communications. Specifically, it prohibited the distribution of deepfakes that misrepresented candidates, election officials, or voting equipment in a misleading way during a defined period before and after an election. The law also allowed individuals, candidates, or election officials affected by such content to seek injunctive relief or damages from those responsible for distributing it.
The Court, however, found that AB 2839 violated the First Amendment by restricting constitutionally protected speech. It ruled that the law discriminated based on content, viewpoint, and the identity of the speaker, criteria that require the application of strict scrutiny. While the Court acknowledged that California has a compelling interest in safeguarding election integrity, it concluded that AB 2839 was not the least restrictive means to achieve that goal. Because it failed to align with historically recognized exceptions to protected speech, the statute was deemed overly broad and unconstitutional.
The ruling effectively halts enforcement of the law but leaves open the possibility for California to craft a more narrowly tailored version in the future that balances the state’s interest in election security with free speech protections.
August 4, 2025: United States v. Paxton
A federal appeals court has upheld Texas’ requirement that potential voters must list their identification information in their application for a mail-in ballot.
In Texas, voting by mail is only available for certain groups of people, including elderly voters and people with disabilities. Under Senate Bill 1 passed in 2021, voters must also include an ID number — such as a driver’s license number — on both the vote-by-mail applications and the mail-in ballots and both numbers need to match. Opponents of the law said this provision discriminated against voters with disabilities and that it would not meaningfully cut down on voter fraud.
Prior to this decision, the U.S. District Court for the Western District of Texas had ruled in 2023 that the requirements infringed on the Civil Rights Act.
July 28, 2025: U.S. v. Robert Page
On July 28, 2025, the Orange County Registrar filed an answer in an ongoing lawsuit brought by the US. Department of Justice. The DOJ filed a complaint in federal court, alleging that the Orange County Registrar of Voters failed to enforce the citizenship requirements of the Help America Vote Act (HAVA) and the list maintenance requirements of Section 8 of the National Voter Registration Act (NVRA). The Justice Department claims that the Registrar of Voters has undermined election integrity by concealing the unlawful registration of non-citizen voters and denying access to voter information, in violation of federal voting laws. The Justice Department seeks declaratory relief and asks the court to order the Orange County Registrar to comply with the requirements of HAVA and the NVRA and to provide the unredacted information requested by the Attorney General.
July 18, 2025: State of California, et al. v. Donald Trump, et al.
On March 25, 2025, President Donald J. Trump issued Executive Order No. 14248, Preserving and Protecting the Integrity of American Elections. The order mandates federal agencies to enforce stricter election rules, including requiring documentary proof of citizenship for voter registration, penalizing states that count mail ballots received after Election Day or allow voters to fix minor errors on ballots, and tying federal election funding to compliance with these new standards, regardless of conflicting state laws.
Thirteen states challenged the Executive Order and sought a preliminary injunction to block its implementation. On June 13, 2025, a federal court granted the injunction, halting enforcement while the case proceeds.
Following a recent Supreme Court decision (Casa Inc. v. Trump), which limited courts’ ability to grant relief beyond the parties involved, the federal government asked the court to narrow the scope of the injunction. On July 18, the court agreed and modified the injunction so that it now applies only to the plaintiff states involved in the lawsuit. The broader legal challenge to the Executive Order remains ongoing.