Rose v. Bd. of Election Commissioners for the City of Chicago

Dist. Ct. did not err in dismissing on claim preclusion grounds plaintiff’s lawsuit alleging that defendant’s refusal to put plaintiff’s name on general election ballot due to plaintiff’s failure to meet statutory 4% signature requirement for aldermanic elections violated various constitutional provisions, where state court, in affirming defendant’s decision not to place plaintiff’s name on ballot, had previously rejected plaintiff’s identical claims. Defendant established all three elements for claim preclusion, and fact that instant lawsuit included section 1983 claim that was not present in state court lawsuit did not require different result since section 1983 action presented only different theory of recovery that arose for same facts and circumstances that gave rise to state court action. Ct. also rejected plaintiff’s contention that instant action should have been allowed to proceed since he had inadequate opportunity to litigate his claims in state court.