However, it was not clear whether that estimate was based on all immigrants or only illegal immigrants. In November 2004, the electorate passed Proposition 200, with 56% of voters voting in the affirmative. Exit polls found that 47% of Latino voters voted in favor of the initiative. Implementation A substantial legal battle erupted over the precise definition of "public benefits." Arizona's Attorney General ruled that the law pertains to only discretionary state programs. Federally funded entitlements like food stamps and subsidized school lunches are examples of public benefits to which, given the Attorney General's finding, the new law would not apply. PAN interpreted the proposition to apply the welfare portion of the initiative to the nearly 60 programs contained in Arizona Revised Statutes Title 46, "Welfare." Despite withstanding three pre-election and two post-election lawsuits, at least one lawsuit related to Proposition 200 is still pending. "Yes on 200" filed a post-election lawsuit, initially dismissed in the lower court but currently on appeal, saying that the Attorney General overstepped his bounds when he narrowed the definition of "public benefits." On December 23, 2004, the federal appeals court in Tucson removed an earlier restraining order that had kept the state from implementing the law. The entire law, with one exception, is in effect, using the definition of "public benefits" promulgated by the Governor and Attorney General. State, county, and city workers may be fined up to $700 for each instance in which they provide such benefits to persons who cannot produce evidence of citizenship. Kathy McKee has since started a new group, Protect America NOW, to support similar initiatives in other states. Voter registration and identification at the polls Proposition 200 required, among other things, proof of citizenship to register to vote and voter identification at the polling place. No major elections took place after its adoption before November 7, 2006, and the actual implementation of these two provisions of the proposition remained unclear. Opponents challenged the constitutionality of these requirements upon voters, arguing that such a law could be used to discriminate against ethnic groups, thus violating the Fourteenth Amendment. On October 5, 2006, the United States Court of Appeals for the Ninth Circuit temporarily suspended these requirements, a little over a month before the election. However, the ruling was stayed fifteen days later by the U.S. Supreme Court. In October 2010, the Ninth Circuit held that the requirement to provide