Maksym v. The Board of Election Commisioners of the City of Chicago 

Candidate for mayor must meet two requirements: the voter residency requirement of the Election Code, to be a qualified elector, and the candidate residency requirement of the Municipal Code, of having resided in the municipality for at least one year preceding the election. The "resided in" requirement for candidates, in the Municipal Code, means actual residence, not constructive residence. Candidate Emanuel did not actually reside in Chicago for at least one year next preceding the upcoming mayoral election of 2/22/11. Although candidate did not lose his voter residency status, based on the exception to the residency requirement under the Election Code, for absence "on business of the United States", that exception is not applicable to the residency requirements for candidacy. The Election Code and the Municipal Code, although distinguishable, may be read in harmony. (HALL, concurring; LAMPKIN, dissenting.)