Macomb County Clerk Anthony Forlini has started what he calls “a movement” to compare jury duty questionnaires — specifically the forms where people claim they are not U.S. citizens and therefore ineligible to serve — with voter rolls. The Michigan Department of State is urging caution.
MDOS sent a memo to election officials statewide on Thursday advising them of the potential pitfalls of comparing jury lists to the Qualified Voter File. A copy of the memo, obtained by Votebeat, warns that without collaboration with legal counsel and state election officials, missteps in the process could wrongly strip eligible voters of their registration or expose them to scrutiny.
“It is critical that election officials proceed carefully before cancelling or changing voters’ status in QVF to ensure that U.S. citizens have the opportunity to confirm their eligibility,” the office warns. Following these steps ensures eligible voters “do not have their registrations cancelled, and they are not otherwise accused of improper conduct or subject to undue criminal investigation.”
Comparing the jury pools — and the people who self-select out by claiming a lack of citizenship — with the voter rolls can be a fraught way to find noncitizens. But Forlini says it doesn’t need to be hard.
Forlini began his mission earlier this year, when he announced that he had identified hundreds of people who had sought to be excused from jury duty in Macomb County by saying they weren’t citizens. Of those 230 people, he found 15 that were also on the voter rolls.
Three of those people had also voted in the county, his office found. The Michigan Department of State, upon investigating Forlini’s claim, found that one person had cast a ballot in 2018 despite not being a citizen. Another was a citizen, while the third was under review. State officials also confirmed that some of the other people Forlini’s office had flagged as potential noncitizens based on the jury lists were in fact U.S. citizens after all.
It’s led to a messy fight between the Macomb County Clerk and the Department of State. Forlini has more recently said that of more than 600 people who reported a lack of citizenship in Macomb County in 2025, 18 were at some point registered to vote.
“Do I not, as the county clerk, have a responsibility … of at least looking back and forth to see if there is some similarities?” he told Votebeat on Thursday, adding that he had heard from other clerks who had started reviewing their own voter rolls in the same way. “The system is flawed.”
At least one other clerk has contacted the Department of State about using the jury lists and other databases to check registrations, department spokesperson Angela Benander said Thursday. The Bureau of Elections has also heard “indirectly of one or two others” exploring the idea, Benander said.
Forlini said it should be easy to separate noncitizens in the jury pool lists shared between MDOS and the counties. The Department of State says it isn’t that simple.
When the state sends counties lists of people for jury duty, it is required to include all county residents with driver’s licenses or state IDs — not just citizens. That means that sometimes, the list will include people who aren’t citizens — as well as people who weren’t at the time of registering for an ID but have since naturalized and may or may not have updated their citizenship statuses with the state.
“People often don’t update their citizenship status until they renew their driver’s license, “which may be years later,” the memo says. If the department tried to remove everyone listed as a noncitizen from the driver file, it would also exclude thousands of people who have since become U.S. citizens.
That would mean that “a large number of Michigan citizens who are legally obligated to report for jury service” wouldn’t be called, it continues.
Comparing two databases also comes with practical challenges. While MDOS controls both the Qualified Voter File and the driver file (known as CARS), they are administered by separate divisions within the department, the memo says.
Plus, someone might have a similar name but be a different person, someone might have filled out a form incorrectly, or someone may have falsely claimed noncitizenship to avoid jury duty.
In other jurisdictions around the country, efforts to cross-check jury lists or SAVE, a federal citizenship database, to identify noncitizens has resulted in U.S. citizens being wrongly flagged or even removed from voter rolls.
Dealing with citizenship can be “more tricky” than something like whether a voter has moved, said Marc Meredith, a professor of political science at the University of Pennsylvania and an expert on election administration.
Citizenship changes regularly — roughly 17,000 people become citizens in Michigan each year, the memo notes. Each day that passes after a given list was produced is another day someone may have gained citizenship, Meredith said. Someone on the voter rolls who isn’t a citizen is a concern, he said, but so is wrongfully removing eligible voters.
He said both scenarios are genuine threats, and the debate ultimately hinges on how people weigh the tradeoff. Conversations also polarize quickly.
“You’ll hear people say that we should do everything to avoid a single case [of noncitizen voting], and you’ll hear that one person prevented from voting is too many,” he said. “Most people, I think, would believe the truth falls somewhere in between.”
Noncitizen voting is already illegal and extremely rare. A statewide review last year identified 16 potential noncitizens who may have voted in the 2024 election, Michigan officials said at the time. But the MDOS memo also noted that roughly half of those initially flagged for review were in fact citizens, warning that without the additional review steps the state undertook, “U.S. citizens could have been referred for prosecution.”
The final number — representing a tiny fraction of the more than 5.7 million votes cast in the general election that year — mirrors what has been found by similar reviews in other states. A review in Georgia found 20 noncitizens among its 8.2 million registered voters in 2024.
Even so, the debate around noncitizen voting remains politically potent in Michigan and nationally. Organizers in Michigan said they submitted 750,000 signatures earlier this month for a proposal that would ask voters this fall to amend the state constitution to require would-be voters to show proof of citizenship upon registering. It would also require current voters to do so if the state can’t independently verify their status.
Nationally, President Donald Trump has touted the SAVE America Act, a controversial elections bill that would introduce many of the same provisions federally — going so far as to say he won’t sign any other bills until it passes.
Hayley Harding is a reporter for Votebeat based in Michigan. Contact Hayley at [email protected].
