Henyard v. Municipal Officers of Dolton

Case of first impression regarding whether and how Illinois voters can recall their elected municipal officers. Village board adopted a resolution placing referenda on the ballot to establish a recall procedure and to recall the incumbent mayor. The circuit court held the referenda were invalid, but the order was stayed and village voters approved both referenda. The appellate court stayed the certification of the results pending its review. On review, the appellate court affirmed the circuit court’s judgment and concluded that the referenda were improperly drafted and, as a result, were ineffective. (CUNNINGHAM and CONNORS, concurring)