Proposition 200, the "Arizona Taxpayer and Citizen Protection Act", was an Arizona state initiative passed in 2004 that basically requires: (a) persons to provide proof of citizenship to register to vote; (b) voters to present a photo identification before receiving a ballot at the polling place; and (c) state and local agencies to verify the identity and eligibility, based on immigration status, of applicants for non-federally mandated public benefits. The proposition also makes it a misdemeanor for public officials to fail to report violations of U.S. immigration law by applicants for those public benefits and permits private lawsuits by any resident to enforce its provisions related to public benefits. The requirement to provide proof of citizenship to register to vote was later ruled invalid in federal court. Authors of the ballot measure, the "Protect Arizona Now" committee, claimed that the provision of state identification and public benefits to individuals without adequately verifying their immigration status gave rise to opportunities for voter fraud and imposed economic hardship on the state. Opponents of the ballot measure asserted that it was anti-immigrant and reminiscent of California's 1994 Proposition 187, as well as disputed the existence of voter fraud and argued that immigrants were important contributors to the state's economy. Proponents Two separate, rival groups supported Proposition 200. The first group was the proposition's sponsor, the Protect Arizona Now (PAN) committee, led by Kathy McKee and supported at the national level by the Carrying Capacity Network (CCN) and Population-Environment Balance (PEB). The second group was the Yes on 200 committee, led by Rusty Childress, a Phoenix-area car dealer, and supported at the national level by the Federation for American Immigration Reform (FAIR). There was a split within PAN, which McKee described as an "attempted hijacking of a local effort by greedy, out-of-state interests"; this split highlighted an ongoing feud within the immigration reduction movement between FAIR and the other two groups dating back to at least 2003, with CCN and PEB issuing frequent statements accusing FAIR (as well as NumbersUSA) of being "reform lite" and "undermining real immigration reform." PAN was formed by McKee and Childress, who became its chair and treasurer, respectively. The PAN National Advisory Board was chaired by Dr. Virginia Abernethy, and included Dr. David Pimentel and Marvin Gregory. Childress later joined a separate effort, Yes On 200, organized by FAIR. During the signature gathering campaign, McKee accused Childress of withholding