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Florida State Conference of the NAACP v. Browning
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Florida State Conference of the NAACP v. Browning

2008 Eleventh Circuit ruling on Florida's 'no match, no vote' registration law.

Florida's exact-match registration rule, upheld against preemption claims in Florida State Conference of the NAACP v. Browning on 3 April 2008, survived a fresh federal challenge on 29 September 2026, when a judge in Orlando dismissed Florida Rising Together's suit for lack of standing.

Last refreshed: 1 October 2026

Timeline for Florida State Conference of the NAACP v. Browning

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Background

Florida's exact-match rule, the subject of this 2008 case, still applies for the 3 November 2026 vote. On 29 September 2026 a federal judge in Orlando dismissed Florida Rising Together's challenge to the exact-match requirement because the group had not shown standing, and gave it until 15 October to file again. The 2026 challengers lost on standing; the 2008 challengers had standing and lost on the merits.

The Eleventh Circuit decided the case on 3 April 2008, reported at 522 F.3d 1153. Judge Gerald Tjoflat wrote the majority, joined by Judge Dubina, and Judge Barkett dissented. The Florida NAACP, the Haitian American Grassroots Coalition and the Southwest Voter Registration Education Project sued Secretary of State Kurt Browning over Florida Statutes section 97.053(6). In force from 1 January 2006, it obliged first-time registrants to supply a driver licence number or the final four digits of a Social Security number that a state or federal database could confirm.

the Court reversed the preliminary injunction, finding the law not preempted by the Help America Vote Act or by the Civil Rights Act's bar on rejecting voters over immaterial errors. Barkett's dissent said the rule had kept over 14,000 citizens, the vast majority of them minorities, off the rolls. The ruling remains the appellate authority any new challenge to the rule must get past.

Common Questions
What was Florida State Conference of the NAACP v. Browning about?
It was a challenge to Florida's 2005 law requiring a first-time registrant's driver licence or last four Social Security digits to match a database. The Eleventh Circuit reversed an injunction against the law on 3 April 2008.Source: Florida State Conference of NAACP v. Browning, 522 F.3d 1153 (11th Cir. 2008)
Did the court uphold Florida's no match, no vote law in 2008?
The Eleventh Circuit found the law not preempted by the Help America Vote Act or the Civil Rights Act and reversed the preliminary injunction against it. Judge Barkett dissented.Source: 522 F.3d 1153 (11th Cir. 2008)
How is Browning different from the 2026 Florida Rising case?
In Browning the challengers got past standing and lost on the merits. In September 2026 a federal judge dismissed Florida Rising Together's challenge to the same rule for lack of standing without reaching the merits.Source: 522 F.3d 1153; Florida Rising Together v. Byrd, M.D. Fla. (29 September 2026)
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