signature requirement (Illinois) · Go Syfert
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signature requirement in Illinois

38 Illinois opinions name it 2 courts 1941–2025 6 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Lockhart v. Cook County Officers Electoral Boardgreen
illappct · 2002 · cited in 4 Illinois opinions naming this issue, 2003–2020
2 sentences

2020Aug. 21, 2003)). -6- ¶ 33 “ ‘The primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters.’ ” Lockhart, 328 Ill.

2005Then we stated that other courts have held, more logically, that the "primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters." Heabler, 338 Ill.App.3d at 1062 , 273 Ill.Dec. 680 , 789 N.E.2d 854 , citing Lockhart v. Cook County Officers Electoral Board, 328 Ill.App.3d 838, 844 , 262 Ill.Dec. 968 , 767 N.E.2d 428 (2002); Huskey v. Municipal Officers Electoral Board, 156 Ill.App.3d 201, 206 ,

34
Heabler v. Municipal Officers Electoral Boardgreen
illappct · 2003 · cited in 4 Illinois opinions naming this issue, 2005–2015
2 sentences

2015As noted, "the primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters." Heabler v. Municipal Officers Electoral Board, 338 Ill.

2015As noted, "the primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters." Heabler v. Municipal Officers Electoral Board of the Village of Lakemoor, 338 Ill.

34
Merz v. Volberdinggreen
illappct · 1981 · cited in 9 Illinois opinions naming this issue, 1987–2021
2 sentences

2015The court noted that "[t]he primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters" and that removing the candidates' names from the ballot would penalize "not only the candidates themselves, but also the voters." Id.

2015The court noted that "[t]he primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters" and that removing the candidates' names from the ballot would penalize "not only the candidates 8 themselves, but also the voters." Id.

29
Shuk Fan Cheung Lum v. Lumgreen
illappct · 1998 · cited in 2 Illinois opinions naming this issue, 2015–2015
2 sentences

2015An unattested will is not a “will.” See In re Estate of Lum, 298 Ill.

2015An unattested will is not a “will.” See In re Estate of Lum, 298 Ill.

22
Bachmann v. Kentgreen
illappct · 1997 · cited in 2 Illinois opinions naming this issue, 2001–2001
2 sentences

2001Sanctions for the failure to comply with the signature requirement are discretionary. 155 Ill. 2d R. 137; Bachmann v. Kent, 293 Ill.

2001Sanctions for the failure to comply with the signature requirement are discretionary. 155 Ill. 2d R. 137; Bachmann v. Kent , 293 Ill.

22
Robert Briscoe v. Stanley T. Kusper, Jr.green
ca7 · 1971 · cited in 2 Illinois opinions naming this issue, 1981–2005
2 sentences

2005Then we stated that other courts have held, more logically, that the "primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters." Heabler, 338 Ill.App.3d at 1062 , 273 Ill.Dec. 680 , 789 N.E.2d 854 , citing Lockhart v. Cook County Officers Electoral Board, 328 Ill.App.3d 838, 844 , 262 Ill.Dec. 968 , 767 N.E.2d 428 (2002); Huskey v. Municipal Officers Electoral Board, 156 Ill.App.3d 201, 206 ,

1981(Briscoe v. Kusper (7th Cir. 1970), 435 F.2d 1046, 1054 .) While we recognize the State’s interest in regulating elections by setting such requirements, we also recognize the right of qualified voters to cast their votes effectively.

12
Girot v. Keithgreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022Polanco argues that the circuit court erred by not granting relief with respect to his argument that the Board was improperly constituted and was biased against him. “[I]t is indeed a well-settled principle of law that concepts of due process apply to administrative hearings, and the parties are guaranteed the right to a fair and impartial tribunal.” Girot v. Keith, 212 Ill. 2d 372, 380 (2004) (reversing decision of electoral board which refused to grant a motion to disqualify a member who was a material witness), citing Anderson v. McHenry Township, 289 Ill.

11
Roti v. Rotigreen
illappct · 2006 · cited in 1 Illinois opinions naming this issue, 2013–2013
1 sentence

2013Cinkus, 228 Ill. 2d at 210 . ¶ 113 It is important to remember that marks of different sorts may qualify as signatures, as long as the mark “manifests that the instrument has been executed or adopted by the party to be charged by it.” (Internal quotation marks omitted.) Roti v. Roti, 364 Ill.

11
Timmons v. Twin Cities Area New Partygreen
scotus · 1997 · cited in 1 Illinois opinions naming this issue, 2008–2008
2 sentences

2008Jenness, 403 U.S. at 442 , 91 S.Ct. at 1976 , 29 L.Ed.2d at 562-63 ; see also American Party v. White, 415 U.S. 767 , 782 n. 14, 94 S.Ct. 1296 , 1307 n. 14, 39 L.Ed.2d at 761 n. 14 (1974); see also Timmons, 520 U.S. at 358 , 117 S.Ct. at 1369 , 137 L.Ed.2d at 598 (states must enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder).

2008Jenness, 403 U.S. at 442 , 91 S.Ct. at 1976 , 29 L.Ed.2d at 562-63 ; see also American Party v. White, 415 U.S. 767 , 782 n. 14, 94 S.Ct. 1296 , 1307 n. 14, 39 L.Ed.2d at 761 n. 14 (1974); see also Timmons, 520 U.S. at 358 , 117 S.Ct. at 1369 , 137 L.Ed.2d at 598 (states must enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder).

11
American Party of Texas v. Whitegreen
scotus · 1974 · cited in 1 Illinois opinions naming this issue, 2008–2008
2 sentences

2008Jenness, 403 U.S. at 442 , 91 S.Ct. at 1976 , 29 L.Ed.2d at 562-63 ; see also American Party v. White, 415 U.S. 767 , 782 n. 14, 94 S.Ct. 1296 , 1307 n. 14, 39 L.Ed.2d at 761 n. 14 (1974); see also Timmons, 520 U.S. at 358 , 117 S.Ct. at 1369 , 137 L.Ed.2d at 598 (states must enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder).

2008Jenness, 403 U.S. at 442 , 91 S.Ct. at 1976 , 29 L.Ed.2d at 562-63 ; see also American Party v. White, 415 U.S. 767 , 782 n. 14, 94 S.Ct. 1296 , 1307 n. 14, 39 L.Ed.2d at 761 n. 14 (1974); see also Timmons, 520 U.S. at 358 , 117 S.Ct. at 1369 , 137 L.Ed.2d at 598 (states must enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder).

11
Talbott v. Thompsongreen
ill · 1932 · cited in 1 Illinois opinions naming this issue, 1990–1990
1 sentence

1990See Talbott v. Thompson (1932), 350 Ill. 86 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (26)

CaseCitedYears
Jenness v. Fortson green
scotus · 1971
2 sentences

2008Jenness, 403 U.S. at 442 , 91 S.Ct. at 1976 , 29 L.Ed.2d at 562-63 ; see also American Party v. White, 415 U.S. 767 , 782 n. 14, 94 S.Ct. 1296 , 1307 n. 14, 39 L.Ed.2d at 761 n. 14 (1974); see also Timmons, 520 U.S. at 358 , 117 S.Ct. at 1369 , 137 L.Ed.2d at 598 (states must enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder).

2008Jenness, 403 U.S. at 442 , 91 S.Ct. at 1976 , 29 L.Ed.2d at 562-63 ; see also American Party v. White, 415 U.S. 767 , 782 n. 14, 94 S.Ct. 1296 , 1307 n. 14, 39 L.Ed.2d at 761 n. 14 (1974); see also Timmons, 520 U.S. at 358 , 117 S.Ct. at 1369 , 137 L.Ed.2d at 598 (states must enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder).

41984–2008
Atkinson v. Schelling green
illappct · 2013
2 sentences

2021App. 3d 1111 (1981), and Atkinson v. Schelling, 2013 IL App (2d) 130140 , the Board determined that, here, Schmidt, acting as Village Clerk, made a mistake when calculating the signature requirement, based upon: her confusion as to whether the Village was non-partisan; the Du Page County Clerk not providing specific instructions and nomination papers, as it had done in past elections; and the COVID-19 pandemic.

2021App. 3d 1111 (1981), and Atkinson v. Schelling, 2013 IL App (2d) 130140 , which held that candidates could rely upon local election officials’ determinations as to the signature requirement. ¶ 22 The Board noted that the question of reliance was a factual one.

32021–2021
Schultz v. Performance Lighting, Inc. green
ill · 2013
2 sentences

2019Schultz, 2013 IL 115738, ¶¶ 14-15 .

2018Schultz , 2013 IL 115738 , ¶¶ 14-15, 376 Ill.Dec. 448 , 999 N.E.2d 331 .

32015–2019
Illinois State Board of Elections v. Socialist Workers Party green
scotus · 1979
2 sentences

2015Citing Illinois State Board of Elections v. Socialist 8 Workers Party, 440 U.S. 173 (1979), the court further stated, "While we recognize the State's interest in regulating elections by setting such requirements, we also recognize the right of qualified voters to cast their votes effectively." Merz, 94 Ill.

2015Citing Illinois State Board of Elections v. Socialist Workers Party, 440 U.S. 173 (1979), the court further stated, "While we recognize the State's interest in regulating elections by setting such requirements, we also recognize the right of qualified voters to cast their votes effectively." Merz, 94 Ill.

32015–2015
Samuelson v. Cook County Officers Electoral Board green
illappct · 2012
2 sentences

2015App. 81, 91 (1946)), and as noted, we review an electoral board's determination as to whether a candidate has substantially complied with the signature requirement of section 10-3 as a mixed question 12 of law and fact (see Samuelson, 2012 IL App (1st) 120581, ¶ 11 ).

2015App. 81, 91 (1946)), 12 and as noted, we review an electoral board's determination as to whether a candidate has substantially complied with the signature requirement of section 10-3 as a mixed question of law and fact (see Samuelson, 2012 IL App (1st) 120581, ¶ 11 ).

32015–2015
Ramirez v. Chicago Board of Election Commissioners green
illappct · 2020
2 sentences

2022In pertinent part, it provides that “if a candidate seeks to run for township committeeperson, then the candidate’s petition for nomination must contain no less than the number of signatures equal to 5% of the primary electors of his or her party of the township, but no more than 8% of those same electors.” Id.

2022July 1, 2018)). 8 No. 1-22-0712 ¶ 22 ANALYSIS ¶ 23 On appeal, Polanco asserts the following contentions of error: (1) the Board should not have dismissed his objections because he pleaded them with sufficient specificity as required by section 10-8 of the Code; (2) under Ramirez v. Chicago Board of Election Commissioners, 2020 IL App (1st) 200240 , the base year for computing the signature requirement was 2020, not 2018; and (3) the Board’s composition denied him his right to due process of law. ¶ 24 We address the last contention first.

22022–2022
In re M.I. green
ill · 2013
2 sentences

2013In re M.I., 2013 IL 113776, ¶ 16 . ¶ 17 Here, we find that the legislature intended a particular consequence for failing to comply with the requirements of section 20(c) of the Act other than the signature requirement.

2013In re M.I., 2013 IL 113776, ¶ 16 . ¶ 17 Here, we find that the legislature intended a particular consequence for failing to comply with the requirements of section 20(c) of the Act other than the signature requirement.

22013–2013
Libertarian Party Of Illinois v. Rednour green
ca7 · 1997
2 sentences

2008Finally, Druck maintained that section 10-8 of the Election Code virtually eliminates the signature requirement if no one files a challenge. [1] On August 19, 2008, the SOEB filed a cross-motion for summary judgment and argued that the issues raised by Druck have been addressed by the Seventh Circuit in Libertarian Party of Illinois v. Rednour, 108 F.3d 768 (7th Cir.1997).

2008Finally, Druck maintained that section 10 — 8 of the Election Code virtually eliminates the signature requirement if no one files a challenge. 1 On August 19, 2008, the SOEB filed a cross-motion for summary judgment and argued that the issues raised by Druck have been addressed by the Seventh Circuit in Libertarian Party v. Rednour, 108 F.3d 768 (7th Cir. 1997).

22008–2008
People v. Gatlin green
illappct · 2017
1 sentence

2025People v. Gatlin, 2017 IL App (1st) 143644 , ¶ 14.

12025–2025
Anderson v. McHenry Township green
illappct · 1997
1 sentence

2022Polanco argues that the circuit court erred by not granting relief with respect to his argument that the Board was improperly constituted and was biased against him. “[I]t is indeed a well-settled principle of law that concepts of due process apply to administrative hearings, and the parties are guaranteed the right to a fair and impartial tribunal.” Girot v. Keith, 212 Ill. 2d 372, 380 (2004) (reversing decision of electoral board which refused to grant a motion to disqualify a member who was a material witness), citing Anderson v. McHenry Township, 289 Ill.

12022–2022
Jackson-Hicks v. The East St. Louis Board of Election Commissioners green
ill · 2015
2 sentences

2021Louis Board of Election Commissioners, 2015 IL 118929 , which held that the signature requirement in section 10-3 is mandatory.

2021“While the signature requirement may have been aimed at showing candidate initiative and minimum voter appeal, showing candidate initiative and minimum voter appeal is not, itself, the standard.” Jackson-Hicks, 2015 IL 118929, ¶ 37 .

12021–2021
Comprehensive Community Solutions, Inc. v. Rockford School District No. 205 green
ill · 2005
1 sentence

2015“Such review is significantly deferential to an agency’s experience in construing and applying the statutes that it administers.” Comprehensive Community Solutions, Inc., 216 Ill. 2d at 472 .

12015–2015
McAloon v. Northwest Bancorp, Inc. green
illappct · 1995
1 sentence

2015McAloon, 274 Ill.

12015–2015
Help at Home, Incorporated v. Medical Capital, L.L.C., D/B/A Medcap green
ca7 · 2001
2 sentences

2015The appellate court defined the issue as “whether multiple documents may be aggregated to satisfy the signature requirement of Section 2 of the [Act].” Id. at 756 .

2015In short, [Roscetti] sheds little, if any, light on the question of whether multiple documents may be aggregated to satisfy the signature requirement of Section 2 of the [Act], which is the question we must answer in this case.” Id. ¶ 30 The court in Help At Home, Inc. declined to decide “this heretofore unanswered question of state law,” because even if it assumed that HAH could “rely on multiple documents to satisfy the [Act’s] signature requirement,” the court “still would have to conclude that the documents the parties signed *** were insufficient.” Id.

12015–2015
Cinkus v. Village of Stickney Municipal Officers Electoral Board green
ill · 2008
1 sentence

2013Cinkus, 228 Ill. 2d at 210 . ¶ 113 It is important to remember that marks of different sorts may qualify as signatures, as long as the mark “manifests that the instrument has been executed or adopted by the party to be charged by it.” (Internal quotation marks omitted.) Roti v. Roti, 364 Ill.

12013–2013
Vision Point of Sale, Inc. v. Haas green
ill · 2007
2 sentences

2009In Vision Point of Sale, Inc. v. Haas, 226 Ill. 2d 334 (2007), our supreme court overruled an interpretation of Rule 216 that imposed a signature requirement not created by the rule’s plain language and held that denials certified in accordance with section 1 — 109 of the Code of Civil Procedure are sufficient to satisfy the rule’s requirement of service of a sworn statement.

2009Like the signature requirement imposed by this court in Moy and disapproved by the supreme court in Vision Point, the majority’s mandate that the sworn statement be made by the party “has no support in the language of Rule 216.” Vision Point, 226 Ill. 2d at 355 .

12009–2009
Huskey v. MUNICIPAL OFFICERS ELECTORAL BD., VILLAGE OF OAK LAWN green
illappct · 1987
2 sentences

2005Then we stated that other courts have held, more logically, that the "primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters." Heabler, 338 Ill.App.3d at 1062 , 273 Ill.Dec. 680 , 789 N.E.2d 854 , citing Lockhart v. Cook County Officers Electoral Board, 328 Ill.App.3d 838, 844 , 262 Ill.Dec. 968 , 767 N.E.2d 428 (2002); Huskey v. Municipal Officers Electoral Board, 156 Ill.App.3d 201, 206 ,

2005Then we stated that other courts have held, more logically, that the "primary purpose of the signature requirement is to reduce the electoral process to manageable proportions by confining ballot positions to a relatively small number of candidates who have demonstrated initiative and at least a minimal appeal to eligible voters." Heabler, 338 Ill.App.3d at 1062 , 273 Ill.Dec. 680 , 789 N.E.2d 854 , citing Lockhart v. Cook County Officers Electoral Board, 328 Ill.App.3d 838, 844 , 262 Ill.Dec. 968 , 767 N.E.2d 428 (2002); Huskey v. Municipal Officers Electoral Board, 156 Ill.App.3d 201, 206 ,

12005–2005
Robertson v. Robertson green
illappct · 1984
1 sentence

1993App. 3d 323 , 462 N.E.2d 712 , the reviewing court found that the mere initials of the trial judge satisfied the signature requirement of Rule 272.

11993–1993
In Re Marriage of Roberts green
illappct · 1980
1 sentence

1993App. 3d 538 , 406 N.E.2d 1 .) Surely, the same need for certainty which defendant claims dictates that a signature be subscribed by the arbitrator as the sine qua non of a valid arbitration award applies at least equally to the signature requirement of Rule 272.

11993–1993
Lubin v. Panish green
scotus · 1974
11986–1986
Bullock v. Carter green
scotus · 1972
11984–1984
Mid-Town Petroleum, Inc. v. Dine green
illappct · 1979
11982–1982
Vaughan v. Millikin National Bank neutral
illappct · 1931
11972–1972
Johnson v. Mueller neutral
illappct · 1952
11972–1972
Doubler v. Doubler green
ill · 1952
11972–1972
People ex rel. Brockamp v. Chicago & Illinois Midland Railway Co. neutral
ill · 1913
11941–1941

Statutes the citing opinions construe

IL § 10 ILCS 5/10-10.1 (6) IL § 10 ILCS 5/10-3 (6) IL § 10 ILCS 5/10-8 (6) IL § 10 ILCS 5/7-10 (5) IL § 735 ILCS 5/2-615 (5) IL § 750 ILCS 28/20 (5) IL § 10 ILCS 5/10-4 (4) IL § 10 ILCS 5/10-9 (4) IL § 750 ILCS 28/35 (4) IL § 750 ILCS 28/45 (4) IL § 10 ILCS 5/1-1 (3) IL § 10 ILCS 5/10-10 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 38 (1941–2025) PA 36 (1982–2026) CA 27 (1969–2025) TX 25 (1948–2026) MO 22 (1982–2023) NY 13 (1928–2025) CT 13 (1983–2022) NC 11 (1940–2025) OH 11 (1991–2025) MD 11 (1914–2022) WA 11 (1973–2025) IN 10 (1913–2015) TN 10 (2000–2026) GA 9 (1907–2023) AL 9 (1985–2003) AZ 9 (1991–2022) AR 8 (1983–2016) MI 8 (1970–2023) ID 7 (1978–2023) CO 7 (2002–2025) MN 7 (1981–2016) IA 7 (1909–2025) KY 7 (1961–2026) WI 6 (1980–2020) UT 4 (2011–2024) OR 4 (1984–2023) VA 4 (2001–2023) MA 4 (1982–2024) AK 3 (1982–2021) LA 3 (1989–2024) SD 3 (2011–2026) NM 3 (1995–2012) WV 3 (1992–2019) FL 3 (1994–2009) OK 3 (1917–2000) NJ 2 (2003–2020) MT 2 (1984–2002) KS 2 (2003–2024) MS 2 (2017–2018) NE 2 (1995–1997)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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