On October 20, Gray submitted a public comment to the U.S. Election Assistance Commission (EAC) in favor of a petition filed by the America First Legal Foundation. The group is requesting that the EAC amend federal regulations and the national voter registration form to include a requirement for applicants to provide documents proving U.S. citizenship. The proposal would apply to all states governed by the National Voter Registration Act.

“This is so important. Only United States citizens should be voting in American elections. Period,” Gray said in a written statement. “I stand in complete and total support of America First Legal Foundation’s petition to require documentary proof of United States citizenship to register to vote on the federal form used across the country.”

Gray added that the initiative aligns with President Donald Trump’s Executive Order titled Preserving and Protecting the Integrity of American Elections, describing it as a “key priority” of the former president.

During Wyoming’s 2025 Legislative Session, Gray worked with lawmakers to pass House Enrolled Act 57, which requires voters in the state to show proof of both U.S. citizenship and Wyoming residency when registering to vote. The law applies to all state and local elections.

Opponents of stricter registration requirements warn that proof-of-citizenship laws could disproportionately affect naturalized citizens, elderly voters, and those born in rural areas who may lack immediate access to documents such as birth certificates or passports. They argue that these policies create unnecessary barriers that could suppress voter turnout among lawful voters.

Legal challenges over similar laws have surfaced in other states. In 2018, a federal court struck down a Kansas law requiring documentary proof of citizenship to register to vote, ruling that it violated the National Voter Registration Act’s intent to simplify and standardize the registration process. The court found that the state failed to demonstrate evidence of significant noncitizen voting.

Civil rights groups also note that the federal voter registration form already includes an oath requiring applicants to affirm, under penalty of perjury, that they are U.S. citizens—a safeguard they say is sufficient without adding new documentation hurdles.

Supporters of the new petition, including Gray, maintain that additional verification steps are “common-sense” measures to protect election integrity. But opponents counter that the proposal answers a problem that data show barely exists, and that it risks narrowing access to the ballot box in the name of preventing fraud.

The full text of Gray’s comment is available through the Secretary of State’s Office.

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