Panel rules for state, rejects Huntington Beach voter ID law

An appeals court struck down a ballot measure passed by Huntington Beach that would have required voters to show ID at the polls for municipal elections starting in 2026.

Attorney General Rob Bonta filed a notice of appeal in May challenging Orange County Superior Court Judge Nico A. Dourbetas' ruling that the city's Charter amendment requiring voter identification falls within the constitutional powers of charter cities to control their election procedures.

On Monday, the 4th District Court of Appeal ruled that California law prohibits municipalities from imposing identification rules beyond those set by the state. People of the State of California et al. v. City of Huntington Beach et al., 30-2024-01393606-CU-WMCJC (Orange County Sup. Ct., filed April 15, 2024).

In a unanimous decision, a three-judge panel held that voter identification laws implicate statewide concerns such as election integrity and voter access.

Huntington Beach City Attorney Michael Vigliotta said in a statement Monday, "The city is reviewing the Appellate Court's decision and evaluating next steps."

The case stemmed from Measure A, a 2023 ballot initiative approved by Huntington Beach voters to amend the city Charter and require voters in its municipal elections to present photo identification.

Before the measure could take effect, the Legislature passed Senate Bill 1174, adding Section 10005 to the state Elections Code. That law, effective from Jan. 1, bars cities and counties from enacting or enforcing their own voter ID requirements.

"All along, Secretary of State [Shirley] Weber and I have maintained that Huntington Beach's voter ID policy is unlawful. When the lower court disagreed, we moved quickly to file an appeal. Now, the California Fourth District Court of Appeal has sided with us," Bonta said in a news release about the decision. "California's elections are already fair, safe, and secure. No city in our state, charter and non-charter alike, can make it more difficult for voters to cast their ballots.

Writing for the panel, Div. 3 Acting Presiding Justice William W. Bedsworth said the statute "addresses election integrity by safeguarding the right of citizens to vote against unnecessary interference by municipalities."

The court found the state's interest in ensuring uniform access to the ballot "reasonably related" and "narrowly tailored" to prevent discrimination and confusion at the polls.

The judge wrote they are "not called upon to resolve this debate" of whether ID should be required to vote.

"Instead, this case presents us a much narrower, simpler question: Is voter identification a matter of 'integrity of the electoral process,' which our Supreme Court has held is a matter of statewide concern, whether presented in statewide or local elections? We conclude it is," the justice wrote.

The opinion emphasized California's history of voter suppression through local practices and echoed arguments by civil rights groups, including the ACLU and Asian Americans Advancing Justice. They argued that local voter ID laws disproportionately harm low-income voters, people of color, and individuals with disabilities.

Huntington Beach claimed its status as a charter city gave it "plenary authority" over municipal elections. But the court rejected that argument, finding that voter identification rules, like voter qualifications, are subject to statewide control.

The appellate panel ordered the lower court to invalidate the charter provision, bar its enforcement, and issue a declaratory judgment that it violates state law. Plaintiffs -- the Attorney General's Office and Secretary of State Weber -- were awarded costs on appeal.