Homeless citizens encounter hurdles that can make registering to vote a difficult process. They often have problems establishing residency. Adding to these obstacles are new voter identification requirements that are gaining ground across the country. It is often difficult for homeless citizens to maintain identification because they are transient, their belongings are sometimes destroyed, and they are sometimes subjected to police sweeps. Thus, many homeless citizens do not have birth certificates or identification cards. However, there are ways to overcome some of these challenges. It is not necessary for a U.S. citizen to have a fixed address to vote. A citizen living in a shelter or on the street can also vote. It is necessary, however, to have a valid mailing address. A voter registration or confirmation card is often sent through the mail after the person has registered. If the card is returned to election officials as undeliverable, then the individual might not be registered. In many areas, organizations, such as shelters, churches and community groups can provide homeless citizens with valid addresses. An Article by the Pew Center on the States mentions that "Judicial opinions in recent years have upheld the notion that requiring a traditional dwelling can pose a hardship to some voters. Court decisions from a number of states have stated that street corners, parks and other public places can be used to establish local voting precincts." Some registrars accept the precise location on the street where the homeless citizen is staying, but the registrars need a mailing address to send voter information, including a registration card, to the individual.