Gill v. Linnabary

Federal 7th Circuit Court
Civil Court
Mootness Doctrine
Citation
Case Number: 
No. 22-1653
Decision Date: 
March 22, 2023
Federal District: 
C.D. Ill.
Holding: 
Vacated and remanded

Ct. of Appeal vacated Dist. Ct.’s order that granted defendants-election officials’ motion for summary judgment in plaintiff’s section 1983 action, alleging that state statutory requirements that plaintiff as independent candidate for 13th Congressional District seat in 2016 obtain signatures representing five percent of voters in prior general election and to have notarized nominating petitions in order to obtain spot on ballot were unconstitutional. Record showed that boundaries of District were significantly altered as result of redistricting that occurred in 2020. As such, Ct. of Appeals vacated District Ct.’s order and remanded case with instruction to dismiss lawsuit based on mootness doctrine, where: (1) District’s geographical boundaries had significantly changed due to redistricting; and (2) plaintiff’s as-applied challenge that pertained to alleged burdens in collecting and notarizing signatures concerned geographical characteristics of pre-2020 District, as opposed to current post-2020 District. As result, federal courts could not provide plaintiff was any effectual relief.