 In a few cases, countries or other governmental entities grant voting rights to citizens and non-citizens alike.In a 2003 paper, David C. Earnest (then a graduate research assistant at George Washington University) surveyed practice of voting rights for resident aliens (or immigrants), concluding that although the practice is surprisingly widespread, the details varied considerably from country to country.In another paper, Earnest compared voting rights for resident aliens in 25 democracies, grouping them into six categories as follows