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Sen. Teresa Manzella urges ballot amendment to limit state, local voting to U.S. citizens
Summary
Senate Bill 185 would amend Article IV, Section 2 of the Montana Constitution to replace the phrase “any citizen” with language specifying that only U.S. citizens may vote in state and local elections; sponsors and election officials said the change would clarify eligibility and would be placed on the ballot if the Legislature approves it.
Sen. Teresa Manzella, D‑District 44, introduced Senate Bill 185 during a House State Administration Committee hearing Friday, asking lawmakers to send a proposed constitutional amendment to voters that would change the state’s elector definition so that only United States citizens are eligible to vote in Montana state and local elections.
Manzella told the committee she heard election security concerns during door‑to‑door conversations and framed the change as clarifying constitutional intent. "If Senate Bill 185 is passed, it would take a large step in the direction of securing our state and local elections as is our constitutional directive to the legislature," she said.
Proponents said the bill does not affect federal elections but would prevent municipalities or local ordinances from authorizing noncitizen voting. Austin James, testifying on behalf of Secretary of State Christi Jacobson, called the change a clarification: "It just makes our constitution clear," he said. Jack Tomczak of Americans for Citizen Voting and other witnesses described polling showing broad public support and cited court opinions they said interpret the word "any" as not equivalent to "only."
Committee members asked practical questions about how the amendment would be applied. Representative Perry asked James to define "citizen," and James replied it means "a citizen of the United States" under naturalization and federal law. Members also discussed a 2021 Phillips County case in which two noncitizens voted in a municipal race after checking a registration box; proponents cited that example as evidence the current language has allowed unintended outcomes.
Witnesses referenced case law and prior state examples: speakers pointed to Lacey v. San Francisco and other litigation arguing that the text "any" does not necessarily bar noncitizen voting in state and local elections. Manzella and proponents framed the proposal as a ballot‑referendum question for Montana voters, not an administrative change by the Legislature alone.
No formal committee action or vote was recorded at the hearing. The bill will remain before the Legislature; if the Legislature passes the amendment, it will appear on a citizen ballot for final approval.
The hearing included public testimony from citizens and organized groups; no opponents identified themselves in the committee record. Committee Q&A focused on definitions of citizenship, implementation across municipal and special‑district elections, and whether the amendment would conflict with federal law. The sponsor said the measure is meant to clarify state constitutional language, not to alter immigration policy.
