Automated Summary
Key Facts
Joseph Severino and Rantch Isquith sought to qualify for the 2026 Illinois Republican primary ballot for Governor and Lieutenant Governor by submitting 6,336 voter signatures. The State Officers Electoral Board invalidated 1,588 signatures, leaving petitioners 252 signatures short of the required 5,000 for statewide candidates. Petitioners requested an extension to challenge the invalidation of 198 additional signatures but were denied by the Board and hearing officer. Their arguments that the Board acted in bad faith and violated constitutional rights were rejected, as the Board's factual findings were supported by uncontradicted testimony. The court affirmed the Board's decision, confirming their names would not appear on the March 17, 2026, ballot.
Issues
- The court evaluated the Board's denial of a three-day extension to file evidence, considering the holiday's impact on petitioners' ability to review signatures and the constitutional argument that strict scrutiny should apply to the deadline rule.
- The court determined that counsel's written appearances and participation in hearings constituted a waiver of jurisdictional objections, rendering the lack of direct service to Isquith immaterial.
- The court examined whether the Board's rejection of 50 signatures for incomplete addresses violated the Election Code's provision for substantial compliance, as the petitioners provided evidence the addresses included sufficient identifying details.
- The court considered if respondent's objections were in bad faith, given his testimony that a team compared signatures to voter registration cards, which petitioners disputed but failed to rebut with evidence.
- The court addressed whether the Board's decision to invalidate 148 signatures for non-registration at the listed addresses was valid, considering petitioners' evidence from the Board's own 'Registration Lookup' website showing signers were registered at those addresses.
Holdings
- The court rejected petitioners' claim that respondent's objections were made in bad faith.
- The court dismissed petitioners' argument regarding lack of service to candidate Isquith.
- The court confirmed the Board's decision to sustain objections to petitioners' nomination papers for Governor and Lieutenant Governor, ordering their names not certified for the March 17, 2026, general primary election ballot.
Remedies
The court affirmed the circuit court's order confirming the State Officers Electoral Board's decision to sustain objections to petitioners' nomination papers for Governor and Lieutenant Governor. As a result, petitioners' names were not certified for the March 17, 2026, general primary election ballot.
Legal Principles
- The court found that the Board's objections to the petitioners' signatures were not made in bad faith, as respondent testified that his team compared signatures on nomination papers with voter registration cards. Petitioners failed to present evidence contradicting this testimony.
- The court applied the manifest weight of the evidence standard to review the Board's factual findings. It affirmed the Board's decision as not against the manifest weight of the evidence, upholding the requirement for 5,000 valid signatures.
Precedent Name
- Burdick v. Takushi
- Municipal Trust and Savings Bank v. Moriarty
- Matos v. Cook County Sheriff's Merit Board
- Anderson v. Celebrezze
- Siegel v. Lake County Officers Electoral Board
Cited Statute
Election Code
Judge Name
- Justice Reyes
- Justice Lampkin
- Justice Rochford
Passage Text
- 19 Petitioners further contend that respondent acted in bad faith by accusing 15 of petitioners' circulators of having committed fraud based on the 'high rate of non-genuine signatures.'
- 1 Held: We confirm the Board's decision sustaining respondent's objections to petitioners' nomination papers for nomination to the offices of Governor and Lieutenant Governor and ordering that their names not be certified for the March 17, 2026, general primary election ballot.
- 22 The order of the circuit court, confirming the Board's decision, is affirmed.