A United States federal judge in Miami has declared a federal law that criminalizes voting by noncitizens unconstitutional, a decision that challenges the Trump administration's efforts to combat alleged election fraud. US District Judge David Leibowitz dismissed the federal case against Chelsea Cox, a Florida resident accused of illegally voting in the 2020 presidential election.

Leibowitz's ruling, issued on Thursday, hinges on the principle that voter qualifications are exclusively determined by individual states under the US Constitution. He stated that the authority to set who can vote rests with the states, not with Congress or federal agencies.

The judge noted that every state already requires U.S. citizenship for voting. Therefore, he concluded, it is up to the state of Florida, which has its own laws against such conduct, to prosecute Cox, rather than the Department of Justice. "Florida can and does," Leibowitz wrote, confirming the state's existing legal framework.

This decision currently applies only to Cox's case and does not set a precedent for other jurisdictions. However, it comes as approximately 45 similar cases remain pending nationwide, and at least four other defendants have raised the same constitutional argument against federal prosecution for noncitizen voting.

Cox, originally from Jamaica, entered the U.S. as a tourist in 1999 and overstayed her visa. Court filings indicate she later obtained a Florida driver's license and registered to vote in 2012 using a fraudulent birth certificate from the U.S. Virgin Islands.

President Donald Trump has repeatedly, and falsely, claimed that widespread noncitizen voting cost him the 2020 election. His administration has framed such voting as a tactic by Democrats to diminish Republican support, though official charges have rarely involved attempts to sway election outcomes.

According to Reuters, the Department of Justice has charged at least 60 people with voting offenses since January 2025. Out of 129 individuals charged with "voting by an alien" since 2021, none were accused of election manipulation, supporting a specific candidate, or receiving payment for their votes. Many of these cases involved lawful permanent residents who registered erroneously or based on incorrect advice.

Cox's attorney, Bruce Udolf, expressed hope that authorities would not pursue deportation against his client, citing her declining health, following the favorable ruling. The case highlights the ongoing legal and political tensions surrounding election integrity and the division of powers between federal and state governments in the United States.