May 14, 2026 12:43PM # Another Data Point Against the Theory That Noncitizens Are Voting En Masse By [Stephen Richer](https://www.cato.org/people/stephen-richer) --- SHARE Listen to this article Generated with [ ElevenLabs](https://elevenlabs.io/) AI technology. Loading the [Elevenlabs Text to Speech](https://elevenlabs.io/text-to-speech) AudioNative Player... ![voter registration](/sites/cato.org/files/styles/pubs_2x/public/2026-01/voter%20registration%20.jpg?itok=FZ2Rr_wl) I’ve written [previously](https://www.cato.org/commentary/trumps-claims-about-noncitizens-voting-are-false-we-can-prove-it) about affirmative investigations into alleged noncitizen voting. For example, Utah [recently audited](https://www.sltrib.com/news/politics/2026/01/23/are-non-citizens-voting-utahs/) its 2.1 million voters and found only one noncitizen registered. These investigations are important because they disprove the theory that a significant number of noncitizens are voting in, and influencing, American elections. Before these affirmative audits, election defenders pointed to the miniscule number of prosecutions against noncitizen voting as evidence that it doesn’t happen. But as I wrote before, just because something isn’t prosecuted doesn’t mean it doesn’t happen. In addition to Utah, [Montana](https://dailyinterlake.com/news/2026/jan/14/initial-review-of-state-voter-rolls-ids-23-potential-noncitizens/), [Alabama](https://www.sos.alabama.gov/newsroom/secretary-state-wes-allen-directs-immediate-removal-186-noncitizens-illegally-registered),[ Michigan](https://www.detroitnews.com/story/news/politics/2025/04/03/michigan-non-citizens-voted-2024-election-jocelyn-benson-voter-rolls-review-drivers-licenses/82791504007/?gnt-cfr=1&gca-cat=p&gca-uir=true&gca-epti=undefined&gca-ft=0&gca-ds=sophi), [Ohio](https://www.ohiosos.gov/office/media-center/categories/press-releases), [Oregon](https://www.opb.org/article/2025/02/10/oregon-elections-officials-noncitizen-voting-doj-cases/), [Louisiana](https://lailluminator.com/2025/09/04/louisiana-election-investigation-finds-79-noncitizens-have-voted-since-1980s/), and [Texas](https://www.sos.state.tx.us/about/newsreleases/2025/102025.shtml) have run at least partial audits in the past year to check for noncitizen voters. Now we have another data point. This time from Pennsylvania. In April, Pennsylvania Auditor General Timothy DeFoor [announced](https://www.abc27.com/news/top-stories/pennsylvania-audit-found-non-citizen-applied-to-vote-through-penndot-overall-system-works-auditor-general-says/?utm_medium=social&utm_source=twitter_abc27News) the findings of an [audit](https://paauditor.b-cdn.net/wp-content/uploads/spePennDOTOAMotorVoterAuditReport041726.pdf) of voter registration forms sent from the Pennsylvania Department of Transportation (PennDOT) to the Pennsylvania Department of State (DOS) between January 1, 2024, and June 30, 2024. That period [encompassed](https://paauditor.b-cdn.net/wp-content/uploads/spePennDOTOAMotorVoterAuditReport041726.pdf) 210,905 unique voter registration forms. Of those, the auditor [determined](https://paauditor.b-cdn.net/wp-content/uploads/spePennDOTOAMotorVoterAuditReport041726.pdf) that 58 forms merited further investigation. Ultimately, the auditor general concluded that during the entire six-month period—out of the 210,905 registration forms—PennDOT improperly sent [*one*](https://paauditor.b-cdn.net/wp-content/uploads/spePennDOTOAMotorVoterAuditReport041726.pdf) noncitizen to the DOS. While the DOS did register that person, he [never](https://www.mcall.com/2026/04/23/pennsylvania-auditor-general-says-motor-voter-system-works-but-improvements-needed/) voted. He is [no longer registered](https://www.mcall.com/2026/04/23/pennsylvania-auditor-general-says-motor-voter-system-works-but-improvements-needed/), and he [no longer lives](https://www.mcall.com/2026/04/23/pennsylvania-auditor-general-says-motor-voter-system-works-but-improvements-needed/) in Pennsylvania. One noncitizen out of 210,905 voter registration forms. Not bad. Of course, that’s 210,905 out of [almost](https://www.pa.gov/agencies/dos/resources/voting-and-elections-resources/voting-and-election-statistics) 9 million total voters in Pennsylvania. And while registration through PennDOT is a popular method of registering, voters can also register online, through the mail, or in-person at a county election office. Still, it’s a data point. And it’s an important investigation because since 2023, Pennsylvania has had automatic voter registration—meaning that Pennsylvanians who acquire a driver’s license through PennDOT are also registered to vote unless they opt out. That makes the link between PennDOT and the Pennsylvania DOS important and worth examining. Will this data point end the allegations of noncitizens voting en masse in American elections or even in Pennsylvania elections? No. But for those who care to know, and who care to look at facts, the proof against such allegations is growing stronger and stronger with each affirmative investigation into noncitizen voters—like this one from Pennsylvania. ##### Related Tags [Constitutional Law](https://www.cato.org/constitutional-law) [![Creative Commons License](/build/cato_2020/images/creative-commons.svg)](http://creativecommons.org/licenses/by-nc-sa/4.0/) This work is licensed under a [Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License](https://creativecommons.org/licenses/by-nc-sa/4.0/).