Formal Complaint Filed with Texas Secretary of State Challenging Federal Voting Law Compliance
AUSTIN, TX — Jeffrey Yuna of Harris County, former candidate for the 38th Congressional District, and Debra Boehm, a voter in Collin County have submitted a formal HAVA complaint with the Texas Secretary of State (SOS), the Hon. Jane Nelson, who is the State’s Chief Election Administrator.
The complaint, supported by Unite4Freedom evidence, seeks a hearing on the record under the longstanding Federal Help America Vote Act (HAVA) (§ 402, 52 U.S.C. § 21112, and 1 Tex. Admin. Code § 81.171) to determine whether Texas is complying with HAVA § 303 in its administration of federal elections.
The complainants are not asking to overturn, contest, or alter any election result. Instead, they seek a record-based HAVA determination concerning Texas’s statewide voter registration list, voter history records, participation records, official-source reconciliation; preservation of source records; and future federal-election compliance.
HAVA Requirements
HAVA § 303 requires Texas to implement and maintain a “single, uniform, official, centralized, interactive computerized statewide voter registration list” that “shall serve as the official voter registration list for the conduct of all elections for Federal office in the State.” This complaint alleges a HAVA Title III violation that has occurred, is occurring, and is about to occur again unless corrected before the next federal election.
This Complaint asks four binary questions about the official Texas record of a single federal election:
- Do the State’s four official counts of voter participation reconcile?
- Is there documented administrative records showing how they reconcile?
- Can the State identify the number that was certified and the source system that produced it?
- Can the State produce the record-chain proof of how the certified number was derived and how it relates to the “single, uniform, official, centralized, interactive computerized statewide voter registration list”?
Evidence of non-compliance
Unite4Freedom’s 2022 and 2024 Election Validity Scorecards and related records provide evidence of an unresolved statewide record issues in the four separate official counts of total voter participation in each federal general election in Texas.
Texas’s four official counts of voter participation:
- TX SOS Official Certified Vote Count2024 GE = 11,388,674 | 2022 GE = 8,102,908
- TX SOS State Voter Roll Count (Voter-history in the SOS database)
2024 GE = 11,101,461 | 2022 GE = 8,120,067 - TX SOS County Voter Roll Aggregate Count (County-uploaded participation records, aggregated through the SOS system)
2024 GE = 11,319,614 | 2022 GE = 8,084,602 - TX Federal Report to the U.S. Election Assistance Commission (Texas’s EAVS F1a submission)
2024 GE = 11,488,820 | 2022 GE = 8,151,590
None of the State’s four official counts of total voter participation in the 2024 federal general election reconcile. The discrepancy between the highest and lowest count is 478,359 voters.
The same issue existed in the 2022 General Election, with a discrepancy of 66,988 voters between the highest and lowest count.
When the State produces four different official counts relating to voter participation in the same federal general election, and those counts are not reconciled or explained through preserved records, Texas has not demonstrated that the statewide list is functioning as the single, uniform, official, centralized record required by HAVA §303.
Evidence impacting 2026
The discrepancy between these counts are of a magnitude that could impact certified federal office outcomes. The March 2026 Cornyn-Paxton U.S. Senate primary in Texas was certified with a margin of 31,818 votes. The discrepancies between each comparison of Texas’s own four official counts of total federal general election turnout—in either 2024 or 2022—is greater than the Cornyn-Paxton margin, with the 2024 discrepancy of 478,359 being over 15 times larger.
Additionally, Unite4Freedom 2026 Democratic and Republican Primary Vote Tampering Reports show unexplained record movement. The snapshots of the official Texas Secretary of State early-voting voter participation files across the 11 days of early voting identified categories of changes, including records that appeared, disappeared, reappeared, or remained absent from later snapshots, large-scale update or removal events, and a reported file-format or column name change affecting county/precinct mapping mid-archive.
The issue is therefore not limited to one past election. If official statewide reporting streams, voter history data, participation records, county source records, public early-voting files, and certified results cannot be reconciled to a preserved authoritative statewide record, the same defect will affect present administration and future federal elections.
In addition to federal law cited above, the complaint rests in Texas State Law including the Texas Administrative Code § 81.171, and Texas Election Code §§ 18.061, 18.065, 18.066, 18.069, 31.001, 31.003, 31.004, 31.005, 1.012 and 66.058. Federal law establishes criminal penalties for election officials who willfully fail to retain and preserve election records, and cause submission of materially defective registrations or ballots, and for malfeasance by election officials acting under color of law by performing such acts as diluting ballots with invalid ones, rendering false tabulations of votes or preventing valid voter registration or votes from being given effect in any election.
Review the filing, to see the complete list of Title III compliance questions and the full list of requested relief.
Visit unite4freedom.com/litigation to view additional filings for New York, Colorado, Missouri and Pennsylvania, and more.
Reach out to Media@Unite4Freedom.com for additional information or to request media appearances.
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