Cliff Sanon really liked to register to vote.
He signed up at least eight times between 2022 and 2026, according to court documents, including one day in 2024 when he submitted two separate applications to register in Philadelphia.
Officials were only happy to accommodate by adding him to their voter rolls. And he went on to cast a ballot in the national election in November 2024.
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The only problem? Federal prosecutors say Mr. Sanon isn’t an American citizen. He’s an illegal immigrant who’s been ordered deported, but can’t be sent back to his home country of Haiti because he could face persecution there.
He’s not alone.
The Justice Department has announced a veritable flood of prosecutions since the start of September, as months of investigative work by the FBI and Homeland Security is suddenly coming to fruition.
The cases have undercut the mantra of liberal voting groups that noncitizens aren’t voting in U.S. elections. It turns out that some have been voting, but nobody was looking for them — until now.
The Washington Times has reviewed more than 200 cases filed over the last decade, some dating back to the first Trump administration, and spotted clear trends on how noncitizens end up on voter rolls, and their motivations for signing up.
For voters in The Times’ database where records do show a party affiliation, 70% are Democrats and 30% are Republicans.
For many, the fact that they registered was a mistake, or close to it. Someone at a government agency or a registration drive outside a grocery store urged them to register, even in cases where the immigrants themselves were reluctant to do so.
Others were deliberate but mistaken about the rules, saying they figured as long-time immigrants, even if they’d never attained citizenship, they’d still earned the right to vote.
Still others had no such illusions or misunderstandings, but signed up anyway.
The election system then failed to weed them out, allowing their registrations to go through — and counting their ballots if they eventually attempted to vote.
Those doing the registering say it’s up to someone later in the process to find illegally registered voters. But election officials later in the process say it’s not their job to police citizenship. They say they trust migrants to be truthful when they register, and are asked to affirm they are indeed citizens.
In short, it’s always someone else who’s expected to stop it. And sometimes nobody does.
“The system that is causing this is brilliantly designed in the sense that nobody has blame. There’s this weird lack of accountability built into the process,” said Christian Adams, a former Justice Department lawyer who now runs the Public Interest Legal Foundation and focuses intently on voter fraud.
Take Mr. Sanon, the man who repeatedly registered in Philadelphia.
He told investigators he usually signed up through voter registration drives, and he did it so often because it was a good way to get a government card with proof of address.
He said he was handed a clipboard and just filled out the form. He usually checked “Yes” for the citizenship box, but one time he left it blank. Another time he checked “No.” He still remained on the rolls.
“I knew I was doing something that was not legit,” he told investigators, according to the court documents in his case.
Mr. Sanon’s case is pending in a federal court. His public defender didn’t respond to a request for comment.
What The Times didn’t find was any broad conspiracy to actively seek out noncitizens. Instead, the records showed an indifference, bordering on negligence, that allowed them to register and didn’t stop them from voting.
Entrapment
Maria DeAraujo, a legal immigrant from Brazil, said she tried to resist signing up to vote but was pressured by the clerk when she went to renew her license at Ohio’s Bureau of Motor Vehicles. The clerk told her that as a long-term immigrant — she’d been here three decades, though still wasn’t a citizen — she needed to register.
Even then, Ms. DeAraujo said, it took the stream of mail from local election officials urged her to show up and cast ballots to get her to turn out in 2016 and 2018.
In 2019, she received a notice from Ohio’s secretary of state saying she was ineligible, and she quickly canceled her registration.
She wouldn’t vote again until 2024, by which time she had won citizenship.
But with President Trump putting a focus on noncitizen voting, state prosecutors brought a case against her in 2024, charging her with casting an illegal vote.
Ms. DeAraujo argued she was effectively entrapped by the BMV clerk and the letters encouraging voting from election officials. After a bench trial, Franklin County Common Pleas Judge Chris Brown agreed, and acquitted her.
“The defendant testified she never thought about voting or intended to vote until a BMV clerk, a government official, told her to register,” Judge Brown said.
Her story is not rare.
The Washington Times’ database of noncitizen voting cases shows that in cases where the location of registration is noted, a motor vehicle office is by far the most common.
Experts have long known that’s a weak spot in the system, with the combination of uncertain immigrants and poorly trained clerks leading to people signing up wrongfully. The clerks usually believe someone down the chain will be investigating and will reject those who aren’t eligible.
But election officials say their checks don’t usually include citizenship. On that score, they say they have to take the word of the applicant who checked “Yes” on the citizenship box and then signed the affidavit attesting to that fact.
Even then, The Times has seen a number of cases where a noncitizen left the citizenship box blank but signed the affidavit and got registered to vote anyway.
In California, Giezell Viduya Adawag has been charged with illegally casting a ballot after she did a same-day registration and vote in the 2024 general election.
She cast a provisional ballot that was counted in Solano County.
When interviewed later by Homeland Security Investigations agents, she said she “didn’t know any better” and was “influenced.” The agents took that to mean she was pressured by her husband.
John Gardner, the interim registrar in Solano County, said when they get a registration — including an Election Day application for a provisional ballot — they enter the data into their system and it gets run through a state database, which looks for duplications and checks state motor vehicle records.
The results come back in seconds. If there are flags, those must be probed. But if not, they go ahead and register the voter and count the ballot.
Mr. Gardner said there were no flags in Ms. Adawag’s case.
Even now, with Ms. Adawag charged criminally, he said there’s not much he can do about her being on the rolls.
“The secretary of state collects all the data from the courts and sends that down to the counties. We really are stuck waiting for the state to provide that information,” he said. “From our perspective ,things are kind of business as usual. Since we have nothing actionable, we just carry on.”
California state officials, meanwhile, don’t believe noncitizen voting is a problem.
When The Washington Times in 2024 sought records of noncitizen voters booted from its rolls, the California secretary of state’s office reported that it didn’t “have any data to report on instances of noncitizens voting or being incorrectly registered and removed from the voting rolls.”
Mr. Adams, at PILF, said that’s because the state actively hides that information.
“They don’t even create a category for data collection on noncitizen removals so they don’t have to tell anybody how many there are,” he said.
Some noncitizens say they weren’t clear on the rules.
Samuel James Hall, a British citizen and legal immigrant accused of voting in Texas in 2020, 2022 and 2024, told investigators he figured once he’d been here 10 years, he was allowed to vote.
In Michigan, Robert Piva said he voted as an experiment in voter fraud, according to state prosecutors.
Lawyers for Mr. Hall and Mr. Piva didn’t respond to inquiries for this story.
Whoopsies
Sometimes migrants acknowledge the records show they voted, but deny they actually did vote — a version of former President Bill Clinton’s “didn’t inhale” explanation for past marijuana use.
“I went but I left it blank,” Erick Ronaldo Soto Mendizabal told an immigration officer, according to court documents detailing Homeland Security’s encounter with the Guatemalan citizen earlier this month.
Mr. Soto claimed he felt pressure to show up even though he wasn’t a citizen. But he said he felt wrong about actually completing a vote for a candidate.
In Pennsylvania, Joyce Donovan, a Kenyan citizen, delivered a similar explanation to DHS agents when they confronted her earlier this month.
“Donovan stated when she did vote she submitted the voter form to be scanned but did not choose a candidate and scanned the unfilled out form,” Robert Mayer, an agent with Homeland Security Investigations, said in a court filing.
Back in California, Pamela Arbues Line, a citizen of the Philippines, told agents she submitted a ballot in 2024 but tried to withdraw it. But she later admitted she didn’t actually take any steps to carry that out.
The Washington Times’ database reveals that the vast majority of those who cast ballots are legal permanent residents.
Still, more than two dozen cases involved illegal immigrants who ended up on the rolls and, often, managed to cast ballots.
In Massachusetts, Lina Maria Orovio-Hernandez, an illegal immigrant from Colombia, registered and voted under the stolen identity she’d been using for two decades.
She was convicted at trial not only of voter fraud but passport fraud and stealing more than $400,000 in public benefits. She collected food stamps, disability and rental assistance, all under her stolen name.
In Florida, Carlos Jose Abreu, an illegal immigrant from the Dominican Republic, stole someone else’s identity to avoid kidnapping and sexual assault charges in New Jersey. He ended up registering and voting under his assumed name.
He’d taken the name of a Puerto Rican — a common theme in illegal immigrant stolen identity cases, because Puerto Ricans are American citizens.
Now the real citizen, identified in court documents by initials CRV, has a criminal record he never earned, and a record of debts and bank accounts he didn’t actually accrue. He struggled to obtain assistance after Hurricane Maria because of the confusion in his financial history.
For good measure, Abreu also claimed the pandemic stimulus checks CRV should have gotten.
Then there’s Chelsea Cox, who prosecutors say is an illegal immigrant from Jamaica.
She registered in 2012 and voted in that year’s general election and again in 2016, 2018 and 2020.
She was charged last year with illegal voting but a federal judge, in a stunning decision earlier this month, ruled that the federal law criminalizing noncitizen voting was unconstitutional. Judge David Leibowitz said the Constitution grants states, not Congress, the power to determine voter qualifications.
He tossed the case against Ms. Cox.
The Justice Department has appealed that decision and so far, no other court has adopted Judge Leibowitz’s reasoning. Indeed, where it has been raised in the weeks since it was issued, courts have rejected it.
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