Part of the rebuttal of Mr. O'Keefe's video was a "fact check" from Think Progress, which claims that one of the "non-citizens", Zbigniew Gorzkowski, was featured in a news article in 2008 which called him a citizen:
Customers flock through the red door of Zbigniew “Ziggy” and wife Halina Gorzkowski’s European grocery and flower shop to buy one of the 12 varieties they sell. The pierogis and 400 eastern European food items and flowers are also punching the naturalized citizen couple’s ticket for their version of the American Dream.
Think Progress said that they found the article by doing a simple Nexis search. Note having a Nexis account, I went straight to the web site of the newspaper in question (the News and Observer). On the News and Observer web site, the portion of the story about Mr. Gorzkowski is:
So what should we conclude? Perhaps Nexis's version of the article matches Think Progress? Since Nexis says "call our sale representative if you want an account, I assume I can't afford to check that way. My library has access to Nexis, and I couldn't find the article searching there, but I'm not sure if they had the same type of subscription as Think Progress. So perhaps Think Progress published the honest result of their search.
On the other hand, perhaps Think Progress found the version on the News Observer site and didn't find the story convincing. So they created their version and wrapped it around a Nexis search, knowing that most people don't have access to Nexis.
As an aside, it was about 150 comments into the over 400 to the posting when somebody finally asked about the News Observer web site article. No response to this from Think Progress that I'm aware of.
Unfortunately, I don't know any way to determine the truth of this little "fact check" episode. Of course, whichever version of the news article is true it doesn't answer the question of Mr. Gorzkowski's citizenship (and I'm not expressing an opinion either way).
In terms of Mr. O'Keefe's claims about non-citizens, it appears that O'Keefe got ahold of jury duty records and extracted a list of those excused for being non-citizens. He then compared this to voting records. Both his "non-citizens" were excused from jury duty for not being citizens, and both were registered to vote. The first person, William Romero, claims to have become a citizen after the jury summons and before this election (and a copy of his naturalization record is online, though again it's from Think Progress.
The second was Mr. Gorzkowski, who says he was naturalized in the 1980's and has voted at least since 2004. So most likely Mr. Gorzkowski is guilty of lying to avoid jury duty, not the right thing to do but getting out of jury duty is a longstanding tradition in this country.