Rose v. Board of Election Commissioner, No. 15-1931 (7th Cir. 2016)
Annotate this CasePlaintiff filed suit against Illinois and the Board after the Board refused to put plaintiff's name on the ballot for a local government election in 2015. The district court dismissed plaintiff's amended complaint. The court concluded that, in this case, all three requirements of claim preclusion are satisfied where the parties in the state and federal actions are the same, and the Circuit Court of Cook County's order dismissing plaintiff's petitions for judicial review are a final judgment on the merits. Nor is there any doubt that the state court was competent to resolve plaintiff's federal claims. Finally, both the state and federal actions are clearly predicated on the same set of operative facts and are therefore the same cause of action under Illinois law; the state court proceedings to which plaintiff voluntarily submitted were constitutionally adequate; and plaintiff had a fair opportunity to appeal the state court's decision. Accordingly, the court affirmed the judgment, concluding that plaintiff had a full and fair opportunity to litigate his claims in state court, and the minimum procedural requirements of the Due Process Clause were met.
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