ATLANTA — It's one of the most startling allegations of voting fraud President Donald Trump made in his effort to overturn the election in Georgia — tens of thousands of ineligible voters cast ballots, raising profound doubts about Joe Biden's victory in the state.
In court documents, the president's lawyers say out-of-state residents, underage voters, felons, dead people and others ineligible to vote did so anyway in Georgia. They back up those claims with what they say is expert analysis of state registration and voting records, and they named names — thousands of people Trump and his attorneys say voted illegally.
But Georgia officials and election experts say Trump's list of illegal voters is riddled with errors, based on faulty analyses and demonstrates a lack of understanding of election laws. In court documents filed this week, they say Trump's list and the analysis that produced it are "highly inaccurate," "wildly unreliable" and "worthless."
A Fulton County Superior Court judge may determine the validity of Trump's claims. But the state's response offers its most detailed rebuttal yet to voter fraud claims that have roiled Georgia politics and inspired doubts about the integrity of elections among the president's supporters.
Secretary of State Brad Raffensperger has repeatedly said there is no evidence of widespread voter fraud in Georgia. Trump's U.S. Attorney General William Barr has said his investigators found no evidence of fraud on a scale that would have changed the outcome of the election.
That has not stopped Trump and his supporters from filing dozens of lawsuits in states he lost, seeking to overturn the results. None of those lawsuits has been successful so far. And now that the Electoral College has formally named Biden the next president, it's extremely unlikely Trump can serve a second term.
But some of the lawsuits are still pending, including one Trump himself filed in Fulton County two weeks ago.
The lawsuit contains many claims of voter irregularities. None is more dramatic than its claim that tens of thousands of ineligible voters cast ballots in Georgia — more than enough to wipe out Biden's 11,779-vote margin of victory.
The lawsuit says allowing the results to stand "constitutes a fraud upon [Trump] and the citizens of Georgia, an outcome that is unlawful and must not be permitted."
The voter fraud claims are based primarily on analyses conducted by two men. The first, Matt Braynard, is a former Trump campaign staffer and election data analyst.
In court documents, Braynard said he compared Georgia registration and voting lists to U.S. Postal Service change-of-address data, a privately maintained national voter registration database and other data.
He said more than 20,000 people who had moved out of state cast illegal Georgia ballots in November: He found at least 4,926 people who cast absentee or early ballots in Georgia but were registered to vote in another state; he found another 15,700 voters who had filed change-of-address forms to move to another state before Election Day.
And he listed the voters in question in hundreds of pages of spreadsheets printed and accompanying his sworn statement.
The other analyst — Bryan Geels, a certified public accountant who owns a data analytics firm — made other startling claims. Analyzing similar data, Geels found more than 305,701 people who he said requested absentee ballots more than 180 days before the November election — in violation of state law.
Geels also found 66,247 voters who appeared to have registered to vote before their 17th birthday — again in violation of state law. And he found 10,315 dead voters and numerous other problems, like scores of people who appeared to have voted before their absentee ballots were issued.
The sworn statements of both analysts contain caveats and disclaimers. They asserted their findings with "a reasonable degree of scientific certainty." They acknowledged their analyses could have produced "false positives" — cases in which votes were legitimately cast. They admitted they didn't have access to state data that would allow them to be certain of their findings.
But Trump's attorneys dispensed with the disclaimers when arguing that a judge should toss out nearly 5 million votes and overturn the election.
"Due to significant systemic misconduct, fraud and other irregularities occurring during the election process, many thousands of illegal votes were cast, counted and included in the tabulations from the contested election for the office of the president of the United States, thereby creating substantial doubt regarding the results of that election," they said in Trump's petition.
The voter fraud claims came under fire even before election experts weighed in.
At a recent legislative hearing, Democratic state Rep. Bee Nguyen, of Atlanta, quizzed Braynard about his conclusions. Nguyen said she found constituents and people she knew on his list of out-of-state voters. She checked property records and, in some cases, visited the voters to confirm they lived in Georgia.
"Many of the names listed on your list are erroneous," she told Braynard. "You allege these voters have committed a felony. There have been no attempts to contact them to verify."
Braynard backpedaled and thanked Nguyen for pointing out the apparent errors.
"In my affidavit, I don't believe I specifically accused anybody of committing a crime," he said. "I said these were indications. Over and over again, 'potential illegal ballots' has been my language."
The word "potential" does not appear in Braynard's affidavit. "In total, it is my opinion that there were 20,312 individuals who cast ballots illegally in the November 3, 2020, election due to their loss of residency status in the state prior to the election," he said in the sworn statement.
In sworn statements filed in court, election experts and state officials offered withering assessments of the analyses by Braynard and Geels.
For starters, they say matching voters to people found in other databases is prone to false matches, in part because different people with identical names and birth dates are not uncommon in large databases. Georgia's registration database includes about 7.7 million people.
The matching problem is made more difficult by the fact that publicly available voter registration data includes only voters' birth year — not their actual birth date. That increases the likelihood of false matches, the experts said. That alone makes the analysts' claims to have found illegal voters dubious, the experts said.
What's more, Braynard's analysis doesn't account for the fact that it's perfectly legal for many people to move out of state temporarily but still vote in Georgia. College students, military personnel, "snowbirds" with vacation homes, people on temporary work assignments or seeking medical care — all of them can retain their Georgia residency. And federal law allows people to cast absentee ballots in presidential elections if they move to a new state before they are able to establish residency.
"Mr. Braynard did not investigate if any of these individuals could legally vote," said Michael McDonald, a political scientist at the University of Florida who has done extensive election research.
Geels similarly fails to account for election law when he concluded that more than 300,000 people may have illegally requested absentee ballots too far in advance of the election. People who are disabled, 65 and older, serving in the military or living overseas can make a single request for absentee ballots for a primary, general election and runoffs.
The experts also dismissed Geels' other claims — including voting by people who are underage, dead or felons — as riddled with potential errors. And state investigators determined that the two specific examples of dead voters casting ballots in the lawsuit did not, in fact, cast ballots.
One expert said other data anomalies Geels uncovered — like votes apparently cast before ballots were issued — should be attributed to simple human error.
"The anomalies Mr. Geels uncovers are generally minor typographical and clerical errors that are neither signs of fraudulent behavior nor lax control over election administration in the state," said Charles Stewart, a political scientist at the Massachusetts Institute of Technology.
Stewart said neither Trump analyst is an expert in the field in which they offer opinions, and he dismissed their claims as "unreliable and without merit."
Though Georgia election results have been certified and its electoral votes cast, the president is still looking for his day in court. He tried and failed to get the Georgia Supreme Court to rule on his case before the electoral vote.
Now his lawsuit is back in Fulton County Superior Court. No hearing date has been set.