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As a long‑time Connecticut voter who has spent many years studying how elections are actually run, my counsel for Secretary of State Stephanie Thomas comes from a place of concern for both the integrity of our voter rolls and the public’s confidence in them.
Connecticut has already demonstrated that it can share sensitive data responsibly through its participation in ERIC, the Electronic Registration Information Center, and it would be in the best interest of our citizens to treat data‑sharing with the federal government in a similar, carefully structured way.
From a practical standpoint, treating the transfer of voter‑roll information to the federal government as an **administrative** function—rather than a political or partisan question—would unlock powerful tools that the state simply does not have on its own. Federal agencies are uniquely positioned to identify non‑citizens who may have been mistakenly added, detect individuals registered in multiple states, flag deceased voters who remain on the rolls, and uncover other inaccuracies that undermine list quality. Used properly, these capabilities would strengthen, not weaken, Connecticut’s control over its own elections by giving your office better, more complete information to maintain accurate and lawful voter lists.
Connecticut already shares detailed voter and motor‑vehicle data with ERIC for the limited purpose of list maintenance and outreach to eligible but unregistered citizens, pursuant to state law that treats such sharing as part of “administration of elections.” This arrangement has set an important precedent: when data‑sharing is tightly scoped, privacy‑protective, and focused solely on election administration, it is both lawful and beneficial to voters. Extending that same logic to the federal government—under clear written agreements, robust data‑security requirements, and strict limits on use—would be consistent with that precedent rather than a departure from it.
There does not appear to be any categorical bar in Connecticut law that forbids cooperation with federal authorities for legitimate election‑administration and enforcement purposes. To the extent current statutes are ambiguous about specific data elements (such as full dates of birth, driver’s license numbers, or partial Social Security numbers), your office is well‑positioned to: (1) interpret them in a way that harmonizes state privacy protections with federal election‑administration needs, and, if necessary, (2) seek clarifying amendments from the General Assembly that explicitly authorize secure, conditional data‑sharing with federal entities. Framing this as a technical, administrative fix—rather than a partisan fight—would help legislators and the public see it as a good‑government measure to modernize our infrastructure and reduce error.
Equally important is how this looks to the public. When the state resists providing data that could be used to improve the accuracy of the rolls, many citizens understandably ask: “What are we hiding?” Even if the legal and technical reasons are sound, the optics can erode trust. By contrast, a posture of proactive cooperation—paired with clear communication that Connecticut will protect voter privacy, tightly limit how data may be used, and insist on high security standards—sends a very different message: that the state has nothing to hide, welcomes scrutiny, and is confident in the integrity of its systems.
For these reasons, I urge SOTS Thomas to:
Handled this way, Connecticut can both honor its voter‑privacy commitments and fully leverage federal capabilities to keep our voter rolls as accurate, up‑to‑date, and trustworthy as possible. That is not a partisan goal; it is a shared interest of every voter in the state, regardless of party.
Thank you for your attention to this matter and for your continued service to the voters of Connecticut.
Connecticut law does restrict how voter registration data can be shared, but it does not create an absolute bar on sharing with the federal government; instead, it conditions and limits that sharing, especially for sensitive fields like full dates of birth, driver’s license numbers, and Social Security numbers. Participation in ERIC is explicitly authorized under state list‑maintenance and election‑administration powers, and nothing in current Connecticut statutes clearly prohibits the Secretary of the State from sharing voter data with ERIC so long as it is for election administration purposes and handled under appropriate privacy and security safeguards.[1][2][3][4][5]
Relevant Connecticut statutes
Connecticut adopted voter‑privacy protections (e.g., 2018 “An Act Protecting the Privacy of Voters”) that limit disclosure of certain data elements such as full dates of birth, portions of SSNs, and driver’s license numbers, while still allowing access to voter registration lists for defined governmental and election‑administration purposes.[2][1]
These laws generally distinguish between:
In practice, that means the Secretary can share more with the federal government than with the general public, but state law still requires attention to privacy and redaction where possible.[1][2]
DOJ lawsuit and federal authority
The Trump DOJ lawsuit against Connecticut seeks an order compelling the Secretary of the State to provide a current electronic copy of the statewide voter registration database “with all fields,” including full names, dates of birth, residential addresses, and either driver’s license number or last four digits of SSN.[6][4]
DOJ bases its demand primarily on Title III of the Civil Rights Act of 1960 (52 U.S.C. § 20703), together with its enforcement authority under the National Voter Registration Act (NVRA) and Help America Vote Act (HAVA), arguing that these statutes permit or require production of the full, unredacted statewide voter list for federal investigative and enforcement purposes.[7][4][8]
Connecticut, like other sued states, has argued that providing an unredacted file conflicts with state privacy protections and that federal law does not clearly require disclosure of the most sensitive identifiers; several federal decisions in other states have allowed states to redact “uniquely or highly sensitive” data (e.g., SSNs, full DOBs) while still complying with NVRA list‑disclosure requirements.[9][10][7]
Is there a state–federal conflict?
At the moment, the conflict is not “federal law says you must keep data secret while state law says disclose,” but the reverse: Connecticut law protects certain voter information from broad disclosure, while DOJ contends federal statutes entitle it to obtain an unredacted dataset for enforcement purposes.[4][6][1]
Courts have generally held that states cannot use their own privacy or public‑records laws to block compliance with valid federal information‑access requirements, but they have also recognized room to harmonize the two by allowing redaction of the most sensitive fields while still providing substantial voter‑list information.[7]
The current DOJ suit against Connecticut is precisely about where that line falls: whether Title III/NVRA/HAVA require Connecticut to hand over unredacted driver’s license and SSN fields (and full DOBs), or whether Connecticut may comply by providing a redacted file consistent with its privacy statutes.[6][4][9]
Sharing with ERIC
ERIC (Electronic Registration Information Center) is a multi‑state compact‑style nonprofit created and funded by member states to improve the accuracy of voter rolls and identify eligible but unregistered citizens.[3][5]
Member states enter a membership agreement under which they periodically send voter and motor‑vehicle records (including some personally identifying information) to ERIC, which then returns list‑maintenance reports (e.g., potential movers, duplicates, deceased registrants) that states use to update their rolls and conduct outreach to unregistered but eligible residents.[5][3]
Courts considering similar interstate data‑sharing agreements have generally upheld them as within states’ authority to administer elections and maintain voter lists, so long as data is used only for election administration and subject to appropriate confidentiality and security constraints.[7]
Nothing in Connecticut’s voter‑privacy statute, as interpreted in those analogous cases, appears to bar secure data‑sharing with ERIC for list‑maintenance purposes; in fact, such sharing is typically treated as part of “administration of elections,” which state law expressly authorizes.[3][5][1]
Connecticut Law Applications
**Does Connecticut law “prevent” the Secretary of the State from sharing voter‑roll data with the federal government?**
No categorical prohibition exists; the Secretary may share data with federal authorities for legitimate election‑administration or enforcement purposes, but state law supports limiting or redacting sensitive elements such as full DOBs, driver’s license numbers, and SSNs, which is what DOJ is now contesting.[4][1][6][7]
**Is sharing with ERIC legal under current statutes?**
Yes, current law permits Connecticut to share voter‑roll and related data with ERIC for the limited purpose of maintaining accurate voter lists and conducting required outreach to eligible but unregistered voters; this fits squarely within the Secretary’s statutory authority to administer voter registration and list maintenance, and courts have treated similar data‑sharing arrangements as lawful.[5][1][3]
Sources
[1] AN ACT PROTECTING THE PRIVACY OF VOTERS. https://www.cga.ct.gov/2018/TOB/h/2018HB-05173-R00-HB.htm
[2] LibGuides Home: Elections & Voting: Laws & Enforcement https://libguides.ctstatelibrary.org/Elections-and-Voting/laws
[3] Electronic Registration Information Center (ERIC) - Ballotpedia https://ballotpedia.org/Electronic_Registration_Information_Center_(ERIC)
[4] Connecticut DOJ Voter Data Access Challenge - Democracy Docket https://www.democracydocket.com/cases/connecticut-doj-voter-data-access-challenge/
[5] Electronic Registration Information Center (ERIC) https://www.pew.org/en/research-and-analysis/articles/2014/01/02/electronic-registration-information-center-eric
[6] [PDF] Complaint - US v Connecticut and Stephanie Thomas https://www.justice.gov/crt/media/1422521/dl?inline
[7] Explainer: Can the Federal Government Force States to Hand Over ... https://statedemocracy.law.wisc.edu/featured/2025/explainer-can-the-federal-government-force-states-to-hand-over-citizens-voter-information/
[8] DOJ sues Arizona, Connecticut over failure to provide voter ... https://www.abc15.com/news/state/doj-sues-arizona-connecticut-over-failure-to-provide-voter-information
[9] Justice Department sues Connecticut and Arizona as part of effort to ... https://www.sfchronicle.com/news/politics/article/justice-department-sues-connecticut-and-arizona-21282012.php
[10] Justice Department sues Connecticut and Arizona over voter data https://apnews.com/article/justice-department-state-voter-data-lawsuits-c26a24df33c8d05793bc9d2e2fad112d
[11] The United States Justice Department announced today that it has ... https://www.facebook.com/WTNH8/posts/the-united-states-justice-department-announced-today-that-it-has-filed-a-lawsuit/1356653433173645/
[12] Laws - Connecticut State Elections Enforcement Commission https://seec.ct.gov/portal/law/lawlanding
[13] ERIC | Public Interest Legal Foundation https://publicinterestlegal.org/eric/
[14] CT sued for refusing to hand voter info to Trump administration ... https://www.yahoo.com/news/articles/ct-sued-refusing-hand-voter-233616581.html
[15] CT sued for refusing to hand voter data to Trump administration https://www.wiltonbulletin.com/news/article/justice-department-ct-voter-data-lawsuit-21280276.php
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