Sbarra-Hagee v. Lake County Electoral Board

Illinois Appellate Court
Civil Court
Election Law
Citation
Case Number: 
2022 IL App (2d) 220193
Decision Date: 
Friday, June 24, 2022
District: 
2d Dist.
Division/County: 
Lake Co.
Holding: 
Circuit court judgment reversed; board decision affirmed.
Justice: 
BRIDGES

At issue was whether the plaintiff qualified as a candidate for the Lake County Board in the June 2022 general primary election. The parties agreed that she did not reside within the board district at the time she filed her nominating papers. The appellate court held that under its interpretation of section 2-3015 of the Counties Code, the candidate was required to reside in the district at the time she filed her statement of candidacy because to find otherwise would create a situation where a candidate would be eligible to run for office, but not to hold that office, a result that previously was rejected by the Illinois Supreme Court. (McLAREN and JORGENSEN, concurring)