Akin v. Smith

Illinois Appellate Court
Civil Court
Election Code
Citation
Case Number: 
2013 IL App (1st) 130441
Decision Date: 
Thursday, April 25, 2013
District: 
1st Dist.
Division/County: 
Cook Co., 4th Div.
Holding: 
Affirmed.
Justice: 
EPSTEIN
Candidates' statements of candidacy substantially complied with Section 7-10 of the Election Code where notarial jurats did not include the phrase "who is to me personally known". Section 7-10 of Election Code contains both mandatory and directory provisions. Substantial compliance can satisfy mandatory statutory requirements as to statements of candidacy. Minor deviation from Code's notarial jurat language did not invalidate the underlying oath as jurat was otherwise in conformance with statute. (QUINN and FITZGERALD SMITH, concurring.)