Figgs v. Municipal Officers Electoral Board for the City of Calumet City

The appellate court considered where the state legislature has the authority under the Illinois Constitution to enact legislation to invalidate a referendum passed by a home rule city’s voters that disqualified candidates for mayor if they hold an elected, paid office created under the Illinois Constitution, such as a state representative. Specifically, the court considered an amendment to the Public Officer Simultaneous Tenure Act. The appellate court held that the Illinois Constitution did confer the power to do so to the legislature and affirmed the judgment of the circuit court in favor of a candidate and against a petition objector. (McBRIDE and HYMAN, concurring)