Gill v. Scholz

Dist. Ct. erred in granting defendants-election officials’ motion for summary judgment in plaintiff-independent candidate’s action alleging that certain voter signature requirements applicable to independent candidates contained in Illinois Election Code violated his First and Fourteenth Amendment rights. Dist. Ct. failed to perform fact-intensive analysis required by Anderson-Burdick balancing test and could not rely on Tripp, 872 F.3d 857, to summarily find that instant five percent signature requirement that mandated that plaintiff obtain 10,754 signatures was permissible. On remand, Dist. Ct. must examine interests put forth by State as justification for burden on plaintiff to obtain instant voter signature threshold.