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Mark Meadows Puts RV Voters on Yellow Alert: North Carolina Voter Residency Law Similar to South Dakota’s

The North Carolina State Bureau of Investigation is investigating whether former White House chief of staff Mark Meadows committed felony perjury by claiming a false residence on his North Carolina voter registration form in September 2020 and casting a vote he was not qualified to cast in the North Carolina 2020 general election. His wife may also face investigation and prosecution for claiming the same fake residence for voting purposes.

The Meadowses’ case may weigh on tens of thousands of “South Dakotans” who claim voting residence at a variety of South Dakota mail-forwarding storefronts while traveling the country in recreational vehicles and living on the road. North Carolina’s voting residence statute reads very much like South Dakota’s. I below I quote the first four main clauses of North Carolina General Statute 163-57 and all four clauses of the notably less verbose South Dakota Codified Law 12-1-4:

NCGS 163-57 SDCL 12-1-4
That place shall be considered the residence of a person in which that person’s habitation is fixed, and to which, whenever that person is absent, that person has the intention of returning… For the purposes of this title, the term, residence, means the place in which a person has fixed his or her habitation and to which the person, whenever absent, intends to return.
A person shall not be considered to have lost that person’s residence if that person leaves home and goes into another state, county, municipality, precinct, ward, or other election district of this State, for temporary purposes only, with the intention of returning. A person who has left home and gone into another state or territory or county of this state for a temporary purpose only has not changed his or her residence.
A person shall not be considered to have gained a residence in any county, municipality, precinct, ward, or other election district of this State, into which that person comes for temporary purposes only, without the intention of making that county, municipality, precinct, ward, or other election district a permanent place of abode. A person is considered to have gained a residence in any county or municipality of this state in which the person actually lives, if the person has no present intention of leaving.
If a person removes to another state or county, municipality, precinct, ward, or other election district within this State, with the intention of making that state, county, municipality, precinct, ward, or other election district a permanent residence, that person shall be considered to have lost residence in the state, county, municipality, precinct, ward, or other election district from which that person has removed. If a person moves to another state, or to any of the other territories, with the intention of making it his or her permanent home, the person thereby loses residence in this state.

Both North Carolina and South Dakota define voting residence in terms of fixed habitation and intention to return from temporary absences. Both states deny voting residence to someone who moves in temporarily but does not intend to stay. North Carolinians and South Dakotans lose their voting residence if they move out with an intent to stay someplace else permanently.

Both states’ voter registration forms underscore the requirement of real, permanent residency. North Carolina asks residents registering to vote to “provide your residential address—where you physically live.” South Dakota requires voters to declare under penalty perjury that they “actually live at and have no present intention of leaving the above address.”

The phrases physically live and actually live seem to give courts plenty of room to reject claims of residence based on occasional visits and demand proof of what any reasonable person would view as regular, everyday habitation, the place where a voter sleeps every night, or at the very least the primary residence the voter maintains as the place to which the voter will return once the voter’s work or college studies or vacation or other interruptions are done. As the South Dakota Supreme Court ruled in Heinemeyer v. Heartland 2008, occasionally sleeping, dining, and getting mail at a place where one pays rent—the basis of RVers’ claim that they “live” in South Dakota—are not enough to establish residency.

Mark Meadows and his wife do not physically live at the residence they claimed when they registered to vote in North Carolina in 2020. The high-profile investigation of this false residency claim could cast an unwelcome light on the tens of thousands of individuals who do not actually live in South Dakota’s mailbox-rental storefronts but have been voting in South Dakota elections.


  1. larry kurtz 2022-03-25 09:28

    White retirees drive South Dakota’s red state failure? White people from Maryland, Minnesota, Colorado and California parachute into South Dakota hoping to isolate themselves from fair taxation and cultural diversity tap into the state’s culture of federal dependence? These slackers are obese Republicans taking advantage of the red moocher state’s regressive tax structure and are now returning in their RVs after a six-month winter and strings of below-zero days.

    The grassland fire danger index will be in the extreme category again today for most of Kristi Noem’s failed red state. Gaia, be merciful.

  2. jerry 2022-03-25 11:19

    Speaking of obese republican slackers, Ginni Thomas, the Supreme Court justice slacker’s bride. It turns out that we may now know who the Kraken really was/is, none other than old chubby herownself, Ginni Thomas. Yep, the Kraken and Mark Meadows were conspiring to kill Democracy before, during and after the January 6th coup attempt and by doing so, show that law and order is meaningless to the current members of the republican Supreme Court.

    Impeach Clarence Thomas and put Mark Meadows in the jail, along with his crooked wife. Lock them up.

  3. Eve Fisher 2022-03-25 13:08

    Madison was the location for one of those RV registration sites, My Dakota Home (and it shut down overnight when it turned out that it had been used by a auto-theft ring in New Jersey to register stolen cars). They used a storefront across the street from the post office for their headquarters, and every RVer was registered at that address. I think it was during the 2012 elections, that a popular local politician (D) was defeated by a landslide a new (R) candidate, which would be fine, except 1500 of those votes came from the address across from the Post Office. I also remember writing then AG Marty Jackley and complaining about voter fraud, etc., and him writing back and saying, let us know when there’s a crime.

  4. Bill McClellan 2022-03-25 14:04

    I’ve lived, worked, and paid my share of taxes for nigh on 40 years here in South Dakota. I am currently getting ready to rv full time, live at a mail box, and continue to vote here. Where do I fit into the equation? Am I a bad guy too?

  5. Cory Allen Heidelberger Post author | 2022-03-25 14:17

    I don’t know, Bill. That’s a good question. Are you planning to establish permanent residency anywhere else?

  6. Arlo Blundt 2022-03-25 16:27

    well….it is about time this tax loophole was closed…the voting fraud needs to be curtailed as well.

  7. Observer 2022-03-25 19:21

    For the “residents” what did they enter on line 7a, 7b & 7c on the PS form 1583 – United States Postal Service Application for Delivery of Mail Through Agent?
    (Applicant Home Address, City and State)? This is used to receive mail through a private mailbox (UPS, Mailboxes, etc.)

  8. Bill McClellan 2022-03-25 20:05

    No Cory, SD will remain our only state of residence, we have family here and intend to visit briefly a couple times a year. High taxes and homeowners insurance are forcing our hands in this. We are looking forward to seeing more of natures wonders in our travels.

  9. Cory Allen Heidelberger Post author | 2022-03-26 08:22

    Observer, I’d love to be able to review those applications and other documents from our RV voters to determine the consistency with which they declare residency. The State of South Dakota makes no such inquiry when registering voters and taking cash for license plates, but a court case focusing on voting residency would surely subpoena such documents.

  10. Cory Allen Heidelberger Post author | 2022-03-26 08:28

    But remember: this issue is complicated. The ACLU has defended full-time travelers’ right to vote. There is nothing inherently wrong with choosing to live on the road, at least nothing that should disqualify one from exercising the right to vote in federal elections. But states and local governments retain the right to restrict participation in their own elections to actual residents.

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