[JURIST] The Tennessee Supreme Court [official website] on Thursday unanimously rejected [opinion, PDF; press release] a movement to overturn the Tennessee Voter Identification Act, ruling that a requirement of government-issued photo ID for voters is constitutional. Chief Justice Gary Wade delivered the majority opinion and Justice William Koch Jr. delivered a concurring opinion [text, PDF] concluding that the provisions of the act protect against voting fraud and are not so severe or unreasonable as to infringe on a voter's rights. In response to the 2011 act, the City of Memphis Public Library began issuing photo ID cards to patrons. Daphne Turner-Golden and Sullistine Bell filed suit against Secretary of State Ted Hargett after their library cards were denied at the polls. The court of appeals ruled that the library cards were covered under the act, ordering election officials to accept the cards during the 2012 general election, but the General Assembly amended the act in April to expressly exclude library cards as a valid form of photo ID.
Thirty-four total states have enacted [background] voter ID requirements varying between strict and non-strict, some requiring a photograph and others not. The Wisconsin Court of Appeals similarly upheld [JURIST report] photo ID requirements as constitutional in May. Texas rights groups filed [JURIST report] a complaint in September in conjunction with the Department of Justice alleging that photo ID requirements discriminate against poor minorities and those in rural areas. A Pennsylvania Commonwealth Court renewed [JURIST report] an injunction in August that will block the state's voter ID law for the third consecutive election.