Last updated on May 26, 2026
Preliminary injunction order finds Indiana failed to justify a 2025 law that blocks student IDs from serving as proof of identity at the polls
An Indiana federal court has blocked a Hoosier State effort to bar student identification cards as proof of a voter’s identity.
The April 14 decision holds that the Indiana law violates college students’ Freedom of Speech rights because it burdens those individuals’ access to the ballot without providing any sufficient benefit to the state.
“[I]ts general applicability notwithstanding, the effects of SB 10 clearly fall more heavily on young voters and students, given they possess a sizable majority of public-university-issued IDs,” U.S. District Judge Richard L. Young wrote. He referred to a means of identifying the Indiana law.
The Indiana law was signed into law in April 2025. The state had previously mandated that a voter’s “proof of identification” generally includes a U.S. government- or Indiana-issued and unexpired or “expired after the date of the most recent general election” document that indicates “the name of the individual to whom the document was issued,” a “name [that] conforms to the name in the individual’s voter registration record,” a “photograph of the individual to whom the document was issued, and “an expiration date.” SB 10 added a clause that says those requirements do “not include a document issued by an educational institution.”
The state argued that a Supreme Court decision in a case called Crawford v. Marion County Election Board barred any relief for the student plaintiffs. A plurality of the justices rejected, in that ruling, an argument that Indiana’s original voter identification statute violated the Constitution. Judge Young explained that Crawford did not control the outcome because the case does not prevent a court from examining impacts of an election law on a group that is not the entirety of the state’s electorate. He also noted that a doctrine based on two other Supreme Court rulings required close scrutiny of facts.
“[A]lthough Crawford will no doubt prove instructive to the proper resolution of this motion, SB 10 imposes different burdens on a different group of voters and is justified by different state interests than the broader voter ID law at issue in Crawford,” the court said. “To hold that Crawford forecloses relief without giving due weight to the particular facts of this case would be to commit legal error.”
Judge Young ruled that SB 10’s exclusion of identification cards issued by educational institutions from the list of documents that validly prove a voter’s identity is discriminatory to college students because they “often lack other options.” Students between the ages of 18-24, he explained, are “the class of voters most likely to use an ID issued by a public university to vote, and the most likely to be burdened by SB 10.”
Indiana claimed that the student plaintiffs did not offer evidence of that impact, but Judge Young pointed to expert witness-supported estimates that about 40,000 students in Indiana are impacted by SB 10. “At any rate, courts applying Anderson-Burdick have found that laws burdening comparable numbers of voters triggered heightened scrutiny,” Judge Young wrote, nodding to the Supreme Court precedent that obligates lower courts to carefully examine limits on voter’s rights to cast a ballot.
The court also explained that, for many students, obtaining proof of identity is not an easy undertaking and that validating residency is also quite difficult.
“Proof-of-residency documents present a new set of hurdles, especially for students who live on campus,” Judge Young wrote. “Those students often lack a mortgage, rental contract, homeowner’s insurance, or utility bills in their own names. They often remain on their parents’ health insurance and are therefore unlikely to receive medical bills at their campus address. And they are less likely to be employed, which means they are also less likely to have pay stubs or tax forms tied to their residence.”
The court also rejected Indiana’s argument that students can easily obtain a form of identification not exempted by the statute. “Obtaining the free ID for voting therefore requires an applicant to surrender their driving privileges everywhere – a burden that weighs heaviest on out-of-state students wanting to vote in Indiana,” Judge Young concluded. “In addition to “finding it difficult to assemble the required documentation, other constraints, like inflexible class schedules, limited access to transportation, and limited funds, make it more challenging to obtain an alternative form of identification.”
And, unlike the situation facing older voters in the Hoosier State, younger voters do not have easy access to options that would mitigate the burdens imposed by the student identification card exclusion. “Absentee voting is limited to voters who meet specific statutory criteria, like illness or old age, and is not normally available to younger voters outside of unique circumstances,” the court found. “Another safety valve, that voters without photo identification may cast provisional ballots that will ultimately be counted, is similarly unavailing. A provisional ballot is counted only if the voter appears in person within ten days of the election to present qualifying ID to the circuit clerk or county election board. But for students who lack ID – and face the same structural barriers to obtaining one after election day as they do before – this is no safety valve at all.”
Judge Young decided that Indiana’s interests do not justify the student identification ban and granted a preliminary injunction against enforcement of SB 10.
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