Since 2005, Indiana has required voters to present proof of identification to cast a ballot in person. For two decades, the state accepted student IDs from state-run universities that met statutory requirements. In April 2025, Indiana enacted Senate Bill 10, which explicitly excluded documents issued by educational institutions from the list of acceptable proof of identification. Plaintiffs, including a current student at Indiana University Bloomington and two voting rights non-profits, sued in May 2025, arguing the law unconstitutionally burdens the right to vote for young people and discriminates against them in violation of the Twenty-Sixth Amendment. While early voting for the primary election began on April 7, 2026, without a ruling on the plaintiffs' request for relief, the district court issued a preliminary injunction on April 14, 2026, enjoining the enforcement of Senate Bill 10. Indiana immediately sought a stay of that injunction from the Seventh Circuit.
The court granted the stay based on the Purcell principle, which admonishes lower federal courts to avoid altering election rules on the eve of an election. The court reasoned that late judicial intervention can lead to disruption, unanticipated consequences, and voter confusion. The court found the risk of disruption to be very serious because the district court's injunction would alter voter eligibility just seven days after voting had already begun. The court emphasized that a federal court unilaterally changing election rules mid-stream violates the Purcell principle, regardless of whether the traditional stay factors are displaced or refined. The court concluded that its federalism-related concerns were dispositive, noting that precedents indicate an appellate court should correct such errors when a lower court intervenes so close to the election date.
Student IDs will remain ineligible for in-person voting during the Indiana primary election. The district court's injunction is stayed pending further appellate review. The court will enter a separate order setting a briefing schedule for the State's appeal, leaving the underlying constitutional questions regarding the Twenty-Sixth Amendment and voting burdens unresolved for the time being.
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