On October 16, 2006, the Supreme Court of Missouri affirmed a trial court decision striking down a state law requiring voters to show Missouri-issued photo identification at the polls. In a per curiam opinion, a 6-1 majority held that requiring voters to present ID cards violates the equal protection and voting-rights clauses of the Missouri Constitution. Applying strict scrutiny analysis, the court found that requiring Missourians to obtain IDs imposes more than a minimal burden on their voting rights, noting that it requires "time, funds and advance planning." The court also held that the provision was not narrowly tailored to the compelling state interest of preventing voter fraud.

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