WASHINGTON, D.C. - Today, in Inter Tribal Council of Arizona, Inc. (ITCA) v. Bennett, No. 08-17115, the Ninth Circuit of Appeals issued a 2-1 opinion which found that Arizona's documentary proof of citizenship requirement for all new voter registrants violates the National Voter Registration Act (NVRA) because the NVRA mandates that states "shall accept and use" the federal voter registration form without additional documentation requirements.