Jackson-Hicks v. East St. Louis Bd. of Election Comm'rs
Annotate this CaseParks, incumbent mayor of East St. Louis, is seeking reelection in the April 2015 election. East St. Louis officials run for office on a nonpartisan basis. Parks’ nominating petitions were subject to Election Code rules governing petitions for independent candidates, 10 ILCS 5/10-3.1, which require signatures by a minimum number of qualified voters of the political subdivision. Under the formula for determining that number, petitions for East St. Louis mayoral candidates were required to have a minimum of 136 valid signatures. Parks filed petitions with 171 signatures. Jackson-Hicks, also a candidate for mayor, filed an objection under 10 ILCS 5/10-8. At a hearing, the attorney for the Election Board presented evidence that at least 48 signatures on Parks’ petitions were invalid; 12 additional signatures were questioned on the grounds that those persons were not registered to vote at the time they signed. The Election Board denied the objection, stating that the objection was in the proper form; that all required notices had been issued and served; and that Parks’ nominating papers had “insufficient signatures.” Despite this deficiency, the Board found “substantial compliance” and ordered that Parks’ name appear on the ballot. The circuit court and appellate court affirmed. The Illinois Supreme Court reversed, finding the minimum signature requirement mandatory.
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