Plaintiff is suing Defendants for violations of the Help America Vote Act (HAVA), alleging that Defendants failed to maintain an accurate statewide voter registration list and used a non-compliant voter registration form that did not require applicants to provide a driver's license number or the last four digits of their Social Security number. Further, Plaintiff claims Defendants admitted the violations but failed to take sufficient corrective actions, such as updating the voter registration list or contacting affected voters to obtain missing information. Lastly, Plaintiff alleges that Defendants' actions resulted in significant non-compliance with HAVA's requirements for elections for federal office.
