Another barrier is securing the appropriate documents themselves. Mrs. Smith, a native of Missouri, had lived and voted in Milwaukee since 2003. After Wisconsin adopted its restrictive voter ID laws, Mrs. Smith attempted to get the required photo identification. To do so, she had to produce a birth certificate that would prove her date and place of birth. But Mrs. Smith, an African American woman born during segregation in 1916, does not have a birth certificate because, like many blacks of her era, she was born at home due to lack of access to a hospital. She attempted to use the ID Petition
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