A new study from Just Facts builds on Electoral Studies’ 2014 paper and estimates that 10% to 27% of non-citizen adults in the U.S. are illegally registered to vote. They estimate that this could potentially total 2 to 5 million voters.

Just Facts also checks the “factcheckers,” namely Glenn Kessler of The Washington Post:

Beyond portraying minimums as best estimates, Kessler also misleads his readers with a half-truth that the 2014 paper estimated “6.4 percent of noncitizens voted in 2008 and 2.2 percent voted in 2010.” What Kessler fails to reveal is that 2010 was a mid-term election, and Richman explained in Kessler’s newspaper that “these are the patterns one would expect to see if the measures retained validity and non-citizens were a group mobilized more in presidential election years than midterms.”

In another ruse, Kessler criticizes and links to a study by Just Facts while coyly describing it as the work of “one researcher.” This avoids the scholarly track record of the organization and the fact that two Ph.D.’s who specialize in data analytics vetted the study and described it as “methodologically sound,” “fair in its conclusions,” and “credible.”