Judge Barlow Dismisses DOJ's Suit for Utah's Full Voter Roll With Prejudice in U.S. v. Henderson

U.S. District Judge David Barlow of the District of Utah dismissed the Justice Department’s suit for Utah’s full statewide voter registration list on October 23, 2026, in United States v. Henderson. The order reads: “the Attorney General’s Motion to Compel is DENIED,” and the complaint, filed Feb. 26, 2026, is “DISMISSED with prejudice.” Barlow, a Trump nominee, held that Utah’s database is “not a record or paper” that comes into the lieutenant governor’s possession, so Title III of the Civil Rights Act of 1960 does not reach it, and wrote that if purpose were the test, “it is clear enough that Title III was intended to address voter suppression.” Because of that holding the court “does not reach Defendants’ other arguments for dismissal,” among them Utah’s privacy laws and the Privacy Act. The NAACP and League of Women Voters of Utah had intervened on Lt. Gov. Deidre Henderson’s side. The department told a Salt Lake City TV station: “We intend to appeal.”

The Salt Lake Tribune counts Utah as the 27th of these suits to be dismissed by a district court; the department has sued 30 states, plus Washington, D.C. Utah was one of the cases still pending when Georgia became the 26th (2026-09-30–georgia-judge-calvert-dismisses-doj-voter-data-suit-26th-loss). “The one appellate court to reach a decision so far upheld” the district court, which is the Sixth Circuit’s Michigan ruling (2026-06-24–sixth-circuit-doj-first-appellate-loss-voter-rolls-michigan); an appeal from Utah would go to the Tenth Circuit.