Bust of Judge James G. Jenkins in Eckstein Hall’s Zilber Forum
The Jenkins Honors Moot Court Competition is a spring-semester invitational program for upper-level Marquette law students who have qualified based on their performance in the fall-semester Appellate Writing and Advocacy course. Proceeding in teams of two, students began writing their appellate briefs in January and have now submitted them.
Next up is the Jenkins Competition’s oral arguments. Students argue in multiple preliminary rounds, with the competition going from the original 12 teams to quarterfinal (8 teams), semifinal (4), and final (2) rounds.
We may pause to note that the primary “technical” result may be a single winning team, but along the way all participants will have learned a good deal about appellate advocacy and the law. And that’s the whole point: We denominate it an honors competition partly because of the way one qualifies and partly because there is no academic credit awarded in connection with the competition.
Let’s get back to the oral arguments: The preliminary rounds of this year’s Jenkins Competition are this coming weekend. In addition to joining Professor Love Koenig in wishing the 24 participating students good luck (see her blog post last month noting and naming them), we may peek ahead to next month.
The finals will occur at 6 p.m. on Tuesday, April 15, in the Law School’s Lubar Center. Anyone in the Law School community (very broadly defined) is welcome to register and attend.
It will be a privilege at this year’s Jenkins Finals for Marquette Law School to welcome—and for the two remaining teams to argue before—three distinguished members of the bench:
Hon. Paul C. Thissen, Justice, Minnesota Supreme Court
Hon. Shelley A. Grogan, L’92, Judge, Wisconsin Court of Appeals
Hon. Rachel M. Blise, L’10, Judge, U.S. Bankruptcy Court for the Eastern District of Wisconsin
The competition is named after the Hon. James G. Jenkins. Having retired as a judge of the U.S. Court of Appeals for the Seventh Circuit, Jenkins served as Marquette University Law School’s first dean (1908–1915). You can read about Judge (or, if you prefer, Dean) Jenkins in a blog post by the late Professor J. Gordon Hylton, which provides a good account of the path of a lawyer in Wisconsin from the mid-1800’s to the turn of the century.
This is the fifth in an occasional series of blog posts occasioned by a visit to Rwanda this past summer. The first, second, third, and fourth can be found at the included links.
In previous blog posts, I have reflected on the powerful experiences that shaped my 2024 visit to Rwanda—observing the resilience of communities, the deep listening that fosters healing, and the transformative work being done to advance justice and reconciliation. These experiences culminated in two pivotal events: our visit to the future site of the Isoko Peace Institute and attendance at the international conference, Listening & Leading: The Art and Science of Peace, Resilience & Transformational Justice, from Rwanda to the World, held in Kigali.
The visit to the site of the Isoko Peace Institute (IPI) and the conference were hosted by Aegis Trust, an organization at the forefront of genocide prevention and peacebuilding. Aegis Trust operates the Kigali Genocide Memorial, which serves as both a site of remembrance and an educational center for reconciliation. The IPI and the conference embodied Aegis Trust’s mission, uniting voices from across the world to explore how Rwanda’s experiences can inform global efforts to counter hate, foster justice, and build sustainable peace.
The Birth of the Isoko Peace Institute
Before the official announcement at the conference, my friends from the Medical College of Wisconsin and I had the extraordinary opportunity to visit the future site of the IPI at the invitation of Freddie Mutanguha, CEO of Aegis Trust.
This invitation-only event was a deeply moving experience. As we stood on that land, surrounded by cultural celebrations, music, and dance, we could feel simultaneously the weight of history and the hope for the future. It was a profound reminder that, even in a nation once devastated by violence, joy and resilience endure. The rhythms of the drums, the grace of the dancers, and the warmth of the community embodied the essence of rebuilding not just structures, but relationships and trust.
Celebrating the announcement of the Isoko Peace Institute
The IPI will serve as a global center for learning, where Rwanda’s lessons on resilience, justice, and healing will be shared with the world—a vision that felt profoundly real in our onsite moment. An ambitious initiative, the IPI will be constructed by Aegis Trust in Bugesera in Eastern Rwanda. Designed as a “sister campus” to the Kigali Genocide Memorial, the institute will be a hub for research, training, and policy development in peace and conflict resolution. It will serve as a space where scholars, practitioners, and future leaders can engage in transformative dialogue and action.
As we stood on that land, we were not just visitors; we were witnesses to a future in the making. The IPI will be more than a building; it will be a beacon of education, reconciliation, and global peacebuilding.
Alice Wairimu Nderitu, the United Nations Under-Secretary-General and Special Adviser on the Prevention of Genocide, and Freddie Mutanguha, the CEO of Aegis Trust.
Shortly after the Isoko Peace Institute visit, we had the privilege of attending the conference in Kigali, a global gathering that brought together some 380 participants from more than 25 countries, all committed to building peace in their own communities. The conference was a testament to Rwanda’s post-genocide transformation—one that has turned unimaginable loss into a model for healing and justice. It provided a space for learning, connection, and action, reaffirming that peace is possible when we choose to pursue it with intention and courage.
A Conference with Global Impact
Throughout the conference, we were honored by the presence of Alice Wairimu Nderitu, the United Nations Under-Secretary-General and Special Adviser on the Prevention of Genocide, who spoke powerfully about the urgency of addressing hate speech and fostering reconciliation. A historic memorandum of understanding (MOU) between the UN Office of Prevention of Genocide and Aegis Trust was signed, ensuring continued collaboration in global peace efforts. Other MOUs were also formalized, strengthening Aegis Trust’s partnerships with the Rwanda Ministry of National Unity and Civic Engagement, the Rwanda Ministry of Education, the Medical College of Wisconsin, and UNESCO. These partnerships will help expand education, research, and practical applications of peacebuilding initiatives worldwide. In my next and final blog in this series, I will discuss the developing partnership between Aegis Trust and the Medical College of Wisconsin.
We learned that the conference was bookended by two significant gatherings which extended its reach. Before the main event, the United Nations Office on the Prevention of Genocide hosted a three-day workshop on hate speech, bringing together forty journalists—particularly from Africa—to discuss the rising dangers of misinformation and incitement. On the other end of the conference, the International Membership Organization for Memorials and Museums Related to Human Rights convened forty museum directors, including Professor Emma Nardi, who leads the global consortium of museums and memorials. These conversations deepened the conference’s impact, reinforcing the critical role of education and storytelling in preventing future atrocities.
Listening as a Tool for Justice
A recurring theme throughout the conference was the power of listening as a tool for transformation. In Rwanda, listening to stories has played a vital role in reconciliation—whether through gacaca courts, community dialogues, or reconciliation villages. One particularly moving experience for the audience was listening to stories from Rweru Reconciliation Village, where genocide survivors and former perpetrators now live side by side. Their journey toward coexistence is about not simply forgiving the past but actively creating a shared future. Their testimonies reminded us that deep listening is itself an act of justice—it acknowledges pain, fosters understanding, and opens the door to healing.
Having previously visited this village just before the start of the conference, I had the opportunity to witness this remarkable community firsthand, an experience I shared in my blog, Rweru Reconciliation Village: A Symbol of Forgiveness and Healing in Post-Genocide Rwanda. Walking through the village, I saw not just a place of survival but one of intentional reconciliation, where courage and humanity intersect. Hearing the villagers speak again at the conference reinforced that reconciliation is—far from a passive process—an active, ongoing commitment to rebuilding trust and dignity. Their stories remain some of the most powerful examples of what is possible when a society chooses peace over division.
Transformational Leadership and Global Justice Practices
The conference underscored the necessity for visionary leadership in post-conflict societies. Rwanda’s leaders have focused not only on rebuilding infrastructure but also on restoring social cohesion. This dual approach—addressing both physical and relational wounds—has enabled the country to make extraordinary strides in just three decades.
Keynote speakers emphasized that effective leadership requires courage, transparency, and inclusivity. Their discussions reinforced that, whether in government, education, or community initiatives, true leadership is about bringing people together and bridging divides.
This theme resonated beyond Rwanda. The conference facilitated an exchange of global justice practices, with attendees sharing lessons from restorative justice programs in the United States, Indigenous peace traditions in Latin America, and community-led reconciliation efforts in Africa to name a few. While every society faces unique challenges, the core principles of listening, humility, and accountability transcend borders.
The Leadership of Freddie Mutanguha
Among the most inspiring figures at the conference was Freddie Mutanguha, the CEO of Aegis Trust, whose personal story is a testament to resilience and purpose. Having lost nearly eighty family members and friends in the 1994 genocide against the Tutsi, Mutanguha transformed his unimaginable grief into a lifelong commitment to genocide prevention and peacebuilding. Under his leadership, Aegis Trust has expanded its impact, from running the Kigali Genocide Memorial to leading educational initiatives that challenge hatred and promote reconciliation worldwide. His work serves as a powerful reminder that leadership in post-genocide societies is not about rhetoric but about action, education, and healing.
The Founding Vision of James and John Smith
The legacy of Aegis Trust is also shaped by the dedication of James and John Smith, who have been instrumental in genocide prevention and historical memory. Their unwavering commitment to justice and peace led to the founding of Aegis Trust, which has played a pivotal role in documenting the history of genocide, supporting survivors, and equipping communities with the tools to prevent future atrocities. Through their leadership, Aegis Trust has built global partnerships, influenced policy, and provided a platform for voices that might otherwise have been forgotten. Their work, alongside leaders like Freddie Mutanguha, illustrates that transformational leadership is about more than responding to the past—it is about actively shaping a future where justice, dignity, and peace prevail.
A Call to Action: Rising Beyond Doubt
The story of Rwanda’s transformation is not just about overcoming the tragedy of genocide—it is about the intentional, courageous work of building a more just and peaceful society. Standing at the future site of the Isoko Peace Institute and participating in the conference were more than moments of reflection—they were calls to action. The resilience and determination I witnessed in Rwanda reminded me that peace is not a passive state; it is an ongoing process that requires collective effort, moral courage, and deep listening.
The creation of the IPI and the powerful exchanges at the conference demonstrated that healing and justice are not abstract ideals—they are lived experiences shaped by bold leadership, honest dialogue, and the willingness to confront painful truths. As Rwanda shares its lessons with the world, the Isoko Peace Institute will become a symbol of what is possible when a nation chooses reconciliation over division, and hope over despair.
Wisconsin has required residents to present a photo ID in order to vote in every November election beginning with 2016[1]. On April 1, voters will have the opportunity to add this requirement as an amendment to the state constitution. It will probably pass. The latest Marquette Law School Poll found 77% support for the ID requirement generally and 73% support for the constitutional amendment.
Supporters of the requirement argue that it’s a good way to prevent voter fraud. Opponents fear that it creates an onerous requirement for eligible citizens without IDs. During federal litigation following the bill’s passage an expert witness estimated that 300,000 then-registered voters lacked an appropriate identification card. Another witness ran a survey which found that 63,000 Milwaukee County residents likely lacked a state ID card.
To my surprise, I could find no more recent analysis of the number of Wisconsin adults lacking a photo ID card. This article is my attempt to answer two questions. How common is it for a Wisconsinite to lack a photo ID? Are there patterns in who lacks them?
Wisconsin Voter Turnout
First, here are some basic facts about voter participation in Wisconsin. Turnout has consistently been very high in this state—typically among the highest in the country.
Opponents feared that the introduction of the photo ID requirement would reduce turnout. This does not appear to have happened, at least in a long-term way.
In 2008, 69.8% of adults voted. This fell ever-so-slightly to 69.6% in 2012. Then, turnout dropped much more noticeably in 2016, down to 66.5% of adults. Voters became much more engaged after Trump’s first election. Turnout jumped to 71.8% of adults in 2020.
Despite a national decline in voter turnout in 2024, it grew in Wisconsin to 72.8% of adults. Turnout was probably highest in Wisconsin out of all 50 states, whether measured as a share of all adults or voting-eligible adults.
Midterm voter turnout grew even faster than presidential turnout after the introduction of the photo ID requirement. Before the requirement, in 2010, 49.9% of adults voted. In 2014, 54.4% participated, growing to 58.8% in 2018. Turnout dipped to 57.7% in 2022.
Concerns about the impact of the photo ID law were particularly high in Milwaukee. Here, turnout dropped from 2012 to 2016 in presidential elections but grew in midterm elections from 2014 to 2018.
These overall turnout trends do not preclude the possibility that turnout would’ve been even higher in 2024 without a photo ID law. But they do imply a fairly low ceiling on the size of such an affect. The share of adults participating in Wisconsin’s democracy has probably never been higher than in the late 2010s and early 2020s, when they were also among the highest rates recorded by any US state since at least 1980.[2]
Current Photo ID Holders by Age
The circa 2011 estimates of people without a photo ID were mostly based on comparing the names in the registered voter database with the names in the DMV driver license database. That approach won’t work anymore, even if one had access to the DMV database (I don’t). Today, if you’re registered to vote in Wisconsin, you almost certainly also hold a photo ID.[3]
Instead, I obtained an aggregated dataset of ID holders by age from the Wisconsin DMV. It includes all kinds of IDs issued by the DMV (not just driver licenses). It does not include other permissible photo IDs, like tribal and student IDs.
My data shows the number of DMV photo ID holders in early 2025. In the chart below, I compare those totals for every year of age, 14 through 84, with our best estimate of the number of Wisconsin residents who were that age in January 2025.[4]
The number of ID holders is shown in red and the population estimate is shown in blue.
About 4% of 14 year-olds hold state ID cards, but the number increases rapidly with each subsequent teenage year. The number of 18 year-old ID card holders is 90% of the estimated 18 year-old population, and this grows to 98% among 24 year-olds. Recall, of course, that many of these young people are college students, and many student ID cards can be used to vote.
After age 24, something interesting happens in the data. Among those ages 25-42, the number of ID card holders noticeably exceeds the total population. The difference peaks at age 33, among whom there are 75,300 residents and 81,700 ID holders.
This excess in ID card holders is evidently the result of population mobility among young adults. The likelihood of moving out of Wisconsin peaks in the late-teens-to-early 30s. When such a person moves from Wisconsin to, say, Minneapolis, their existing ID card does not automatically or immediately expire.
Initial Wisconsin driver licenses last 2 years and renewed licenses expire 8 years after the recipient’s next birthday. So someone who renewed at age 20, then moved out-of-state after college graduation, would potentially be counted as a current Wisconsin photo ID holder until age 28, at least so long as they avoided getting a driver license in their new state.
Wisconsin participates in something called the “State to State (S2S) Verification Service,” along with 41 other states and the District of Columbia. This program alerts state DMVs when a person holding a license in one state receives a license in another (they match on SSNs). The goal is to prevent people from holding licenses in multiple states at once. Notably, Illinois is not a member of S2S (probably related to its still ongoing struggle to become real ID compliant). So Wisconsinites who move to Illinois will likely remain on the list of Wisconsin ID holders for longer than those moving into another neighboring state.
From the mid-40s onward, the number of DMV ID holders and the actual population converge. The degree of correlation is striking.
It’s not just that the general trends are similar. Even abrupt changes are matched in the two data sources. For example, the estimated population falls slowly between ages 75 and 77, sharply from 77 to 79, and slowly again from 79 to 80. This exact pattern is the same in both the population estimates and the ID counts.
Age
Population Est.
ID Holders #
75
53,600
53,700
76
50,100
50,700
77
49,600
49,800
78
42,300
42,500
79
33,300
33,800
80
32,100
32,300
Notice that the number of ID holders still slightly exceeds the population for each age. This reflects, I believe, an unavoidable delay in processing death certificates plus the continued effect of IDs expiring after their holder has left the state.
How Many Adults Lack an ID?
What we’d really like to know is the number of valid DMV ID cards held by a current resident of Wisconsin. . Nobody knows this statistic, but we can estimate its lower bound.
Each year, the Census Bureau estimates the number of people who moved out of Wisconsin in the previous year.[5] It bounces around a bit from one year to another, but typically about 10,000 18 or 19 year-olds and 83,000 adults age 20 or older leave the state.
Standard licenses last for 8 years after your next birthday and initial (or “probationary”) licenses last for two. Knowing this, we can estimate how many recent movers would hold an unexpired Wisconsin ID, if that ID remained valid until its scheduled expiration date.
For the purposes of this calculation I assume that every 18 or 19 year-old mover held a probationary license and every other adult held a full driver license (an overestimate, no doubt). I further assume that people leaving Wisconsin do so randomly with regard to their ID card’s expiration date. Someone leaving the state is equally likely to hold an ID card that they renewed 1 year ago as they are to hold a card expiring in 1 year.
Consequently, I estimate that three quarters of the 76,000 people (age 20 and older) who left the state 2 years ago still hold a DMV ID card that has not yet reached its printed expiration date.
Adding up each year’s fraction of the movers still holding an “unexpired” ID, I get an estimate of 304,000 “unexpired” DMV ID cards actually belonging to someone who no longer lives in Wisconsin.
Subtracting this number from the count of adult DMV IDs, we get 4.43 million ID card holders, or 94% of the state’s adult population of 4.72 million. By this measure, 290,000 adults (6%) would lack a DMV-issued ID card.
Of course, this is the outer boundary of estimates for the non-ID-having population. The actual number must certainly be lower—possibly much lower—thanks to Wisconsin’s participation in the S2S system.
When our hypothetical twenty-something moves to Minnesota after college, their Wisconsin ID will only last until they receive a Minnesota ID to replace it. How long they wait before applying for this ID is unknown. I can find no statistics from the S2S system reporting the number of matches they process.
And we have the issue of Illinois. The Census Bureau estimates that 14,000 people (of any age) made the move from Wisconsin to Illinois in 2023. Thanks to Illinois’ lack of participation in the S2S system, these movers are probably more likely to remain on the books in Wisconsin.
All of this is to say, the plausible share of adult Wisconsin residents without a DMV-issued ID lies somewhere less than 100% and greater than 94%.
What Predicts Fewer ID Holders?
The population without a DMV ID card is evidently small, but it could be concentrated among particular groups of people. To measure this, I designed a linear regression model predicting the ratio of ID holders per 100 adults in each census tract. The dependent variable is adult ID holders as a percentage of the adult population and the independent variables are listed with their coefficients in the table.
Naturally, the largest predictor of more IDs is movers out of Wisconsin. For every 1 percentage point increase in the share of the population who left Wisconsin in the previous year, the number of IDs per 100 grows by 1.6.
The opposite is also true. If more people in the tract are recent arrivals to Wisconsin, the tract has fewer ID cards. As expected, ID cards are also less common in places with more college students and 18-19 year-olds. (Some of these will have student IDs that allow them vote.)
More concerning is the effect of poverty. The number of IDs per adults declines by 0.24 with every 1 point increase in the share of adults living below the poverty line.
A 1-year increase in the median age has a similarly-sized positive effect in increasing the number of ID holders.
All else being equal, a 1 percentage point increase in the Black and Asian populations is associated with 0.27 and 0.18 point increases, respectively, in the share with a photo ID.
Conclusion
The great majority of Wisconsin adults hold a photo ID card from the DMV. The total number of ID holders exceeds the adult population because ID cards often expire years after the holder moved out of the state. After estimating the number of unexpired IDs attributable to those who’ve left the state, I estimate that fewer than 6% of adult Wisconsin residents may lack a DMV photo ID card.
A regression analysis suggests that the adults least likely to hold an ID card are those in their late teens, college students, and new arrivals to the state. College students commonly receive photo IDs which can be used to vote and new arrivals likely just haven’t gotten around to updating their DMV registration.
This leaves young adults who aren’t enrolled in college and adults living in poverty as the two groups most likely to be harmed by the photo ID requirement for voters.
Wisconsin’s voter turnout rates have continued to climb since implementing a photo ID requirement for voters prior to the 2016 election. In 2024, Wisconsin actually had the highest voter turnout rate in the nation. This likely reflects government efforts to make voter ID cards freely available with minimal paperwork, and successful efforts to help more people apply for those cards. Nonetheless, it remains the case that young and poor people are less likely to have a photo ID, though this is not true of racial minorities according to the regression analysis.
[1] The law was originally passed in 2011, but it underwent extensive state and federal litigation that prevented its use in the 2012 and 2014 general elections. See this timeline for more details.
[3] One must present proof of residence in order to register to vote, which could be a current photo ID but could also take the form of, e.g., a utility bill. A photo ID is only required in order to request a ballot. Wisconsin’s voter roll maintenance stipulates that, following each general election, postcards are mailed to every registrant who hasn’t voted in the past four years. If the registrant fails to return the postcard, they are struck from the voter rolls. So, technically, it would be possible for someone without a photo ID to register to vote, never actually cast a ballot, but remain on the voter rolls by faithfully returning the maintenance postcard every two years.
[4] I leave the 85+ population off the graph because that population estimate is given as a total and not by single year of age. The relationship of IDs to population is the same for this age bracket as for other older adults. After adjusting the 2023 population estimates for age specific mortality rates, I estimate that 120,800 adults age 85 and older lived in Wisconsin in January 2025. At that time, there were 121,500 DMV IDs issues to people in the age bracket.
[5] These numbers are collected by the American Community Survey (ACS). The 2024 estimate is unavailable, so I substituted the average of 2022 and 2023. No 1-year estimates were published for 2020 (due to pandemic disruptions to data collection), so I substituted the average of 2019 and 2021.
