On April 28, 2008, the US Supreme Court issued a ruling upholding an Indiana statute that requires voters to present photo identification in order to vote. Justice Kennedy had indicated during oral arguments that he considered the requirement to show ID a minimal inconvenience rather than a measure that could discourage minorities, the elderly, and the poor from voting. Multiple states have recently enacted voter ID statutes. Many have faced constitutional challenges. In April 2012, the Ninth Circuit issued a ruling [PDF] upholding Arizona's photo ID requirement while simultaneously striking down the statute's requirement that voters show proof of citizenship.