The Complaint raises six legal issues: 1) Whether California's implementation of its vote-by-mail laws constitutes an obstacle to Congress's prohibition against noncitizen voting in federal elections; 2) Whether a federal statute prohibiting individuals from voting unlawfully--18 U.S.C. § 611--also restricts state election officials' administration of elections; 3) Whether federal agencies' identification of approximately 20,000 likely noncitizens provides a sufficent basis to segregate their ballots pending citizenship verification; 4) Whether federal election law permits the federal govenrment to require state officials to undertake additional citizenship verification procedures; 5) Whether the United States has standing and a sufficient legal basis to obtain judicial intervention in California's election administration; 6) Whether preventing potentially unlawful votes from being counted justifies delaying the tabulation of ballots belonging to individuals whose citizenship has not been conclusively determined. The United States requests a judgment that California's conduct is preempted by federal law and violates the Supremacy Clause and an order prohibiting California from counting ballots from federally identified likely noncitizens until their citizenship is verified.
