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Eileen Jackson, Appellee v. the Board of Election Commissioners of

September 7, 2012


The opinion of the court was delivered by: Justice Karmeier

JUSTICE KARMEIER delivered the judgment of the court, with opinion.

Chief Justice Kilbride and Justices Thomas, Garman, and Theis concurred in the judgment and opinion.

Justice Freeman concurred in part and dissented in part, with opinion, joined by Justice Burke.


¶ 1 Section 3.1-10-5(b) of the Illinois Municipal Code (65 ILCS 5/3.1-10-5(b) (West 2010)) provides that a person "is not eligible for an elective municipal office if that person is in arrears in the payment of a tax or other indebtedness due to the municipality." The issue presented by this case is whether section 3.1-10-5(b) should have disqualified a candidate named Carmelita Earls from seeking election to the Chicago city council from the 28th Ward in the 2011 municipal election where homestead exemptions on property owned by Earls and her husband were challenged and the couple subsequently elected to waive the exemptions on all but one of the parcels and to pay the Cook County treasurer the additional property tax that would have been due on the parcels had the exemptions not been claimed.

¶ 2 The board of election commissioners of the City of Chicago (the Election Board) ruled that Earls was not disqualified and denied an objection to her nomination papers filed by Eileen Jackson. The circuit court of Cook County upheld the Election Board's decision, but the appellate court reversed, set aside the Election Board's decision, and ordered that if Earls' name could not be removed from the ballot, any votes cast for her would not be counted. 407 Ill. App. 3d 837. We allowed Earls' petition for leave to appeal. Ill. S. Ct. R. 315 (eff. Feb. 26, 2010).

¶ 3 For the reasons that follow, we hold that property tax payable to the Cook County treasurer does not constitute "a tax or other indebtedness due a municipality" within the meaning of section 3.1-10-5(b) and that the additional property tax Earls and her husband paid after the homestead exemptions were challenged did not render Earls ineligible to hold municipal office in Chicago. The Election Board was therefore correct when it rejected Jackson's objection to Earls' nomination papers. The Election Board's decision was properly upheld by the circuit court, and the appellate court should not have overturned the Board's decision on review. The judgment of the appellate court is therefore reversed.


¶ 5 Carmelita Earls and her husband, Aubrey, own, as joint tenants, a home located at 37 N. Long Avenue in the City of Chicago. Aubry applied to the Cook County assessor for a homeowner's exemption for that property for the 2008 tax year. In the application, Aubry specifically averred that he and Earls occupied that property as their "principal residence."

¶ 6 Earls and Aubry also own two additional properties in the City of Chicago, 552 and 555 N. Lawler Avenue. Just as he had with the property at 37 N. Long Avenue, Aubry applied to the Cook County assessor for a homeowner's exemption for both of those properties for the 2008 tax year. These exemptions were not identical. Whereas the application for 555 N. Lawler Avenue sought the same general homestead exemption as the application for the exemption on 37 N. Long Avenue, the application for 552 N. Lawler Avenue requested a "long-time occupant" homestead exemption (see 35 ILCS 200/15-177 (West 2008)) and stated that Earls and Aubrey had owned and occupied the property during the period between January 1, 1998, and January 1, 2008, and met certain other qualifications related to their income.

¶ 7 The Cook County assessor allowed the homestead exemptions on all three properties, thereby reducing the amount of property tax Earls and her husband were required to pay on those properties. The exemptions were subsequently carried forward, reducing the couple's real estate tax bills for the 2009 tax year, which were payable in 2010.

¶ 8 In 2010, Earls decided to run for the office of alderman for the 28th Ward of the City of Chicago in the next general municipal election, which was scheduled to take place on February 22, 2011. Under section 3.1-10-5(b) of the Illinois Municipal Code, a person "is not eligible for an elective municipal office if that person is in arrears in the payment of a tax or other indebtedness due to the municipality." 65 ILCS 5/3.1-10-5(b) (West 2010). Because the position of alderman is an "elective municipal office" within the meaning of this statute, Earls wanted to insure that she was in compliance with the law. She therefore checked with the City to see if she owed it any money.

¶ 9 The City maintains a special office to field such inquiries. That office, officially known as the "Indebtedness Check Unit" of the City of Chicago department of revenue's accounts receivable division, responded to Earls' request in writing. By letter dated November, 17, 2010, it advised her as follows:

"The Department of Revenue performed a thorough indebtedness investigation at the request of the individual referenced above[, Carmelita Earls,] on the date indicated for outstanding debt owed to the City of Chicago.

Please accept this as confirmation that no outstanding debt was found across any of the debt types, Parking, Water, Administrative Hearings, Inspection Fees, Cost Recovery and Tax/Licensing."

¶ 10 Five days after this statement was issued, Earls filed nomination papers for her aldermanic bid with the Election Board. Eileen Jackson promptly filed a petition objecting to Earls' candidacy. See 10 ILCS 5/10-8 (West 2010). Jackson asserted numerous grounds in support of her petition. Chief among these were that Earls had failed to submit a sufficient number of valid signatures to entitle her to be placed on the ballot for alderman, that Earls' nomination papers were not securely fastened as required by law, that Earls was not a resident of the ward in which she was seeking to run, and that Earls was not eligible for elective municipal office under section 3.1-10-5(b) of the Illinois Municipal Code (65 ILCS 5/3.1-10-5(b) (West 2010)) because she was in arrears in payment of taxes or other indebtedness to the City.

¶ 11 Although the Chicago department of revenue had declared that Earls owed no outstanding debt to the City for the various items identified in the statement of indebtedness, Jackson's petition asserted that Earls was nevertheless ineligible because she was in arrears on her property tax. Though records showed no overdue balance on Earls' property tax obligations, Jackson asserted that Earls and her husband had paid less than they should have by fraudulently obtaining homeowner exemptions to which they were not entitled.

¶ 12 Jackson's objection petition was first taken up by the Election Board on December 6, 2010. Following various procedural developments not relevant here, an evidentiary hearing on Jackson's petition was held before an Election Board hearing officer on December 22, 2010. At that hearing Jackson elected not to contest that Earls' nomination papers were, in fact, supported by a sufficient number of valid signatures. She withdrew any challenge to Earls' residency, and she produced no evidence that Earls' petitions had not been properly bound. The only matter in dispute was whether Earls was in arrears in payment of taxes or other indebtedness and therefore ineligible for municipal office under section 3.1-10-5(b) of the Illinois Municipal Code (65 ILCS 5/3.1-10-5(b) (West 2010)) at the time she filed her nomination papers.

¶ 13 In support of her tax/debt arrearage claim, Jackson relied on a letter dated December 6, 2010, from the Cook County assessor's office informing Earls of a problem with the homestead exemptions on the three properties she owned with her husband. The letter explained that homestead-exempted property must be the " 'principal dwelling place of members of the household on January 1 of the taxable year' [(see 35 ILCS 200/15-175, 15-177 (West 2008)) and that a] taxpayer is only entitled to one homeowner exemption on one residence." The letter went on to inform Earls and her husband that an investigation had disclosed that they had received homeowner exemptions for all three properties they owned in the City.

¶ 14 According to the letter, application of the homeowner's exemption to the 555 N. Lawler Avenue property had reduced the Earls' real estate tax liability for that parcel by $963.20 in 2008 and by $669.16 in 2009. For the property at 552 N. Lawler Avenue, the homestead exemption saved Earls and her husband $1,624.29 in 2008 and $1,220.60 in 2009. The assessor's letter notified Earls and her husband that they were required to provide proof of residency for one of the three properties if they wished to avail themselves of the homestead exemption and that with respect to the other two properties, they would be required to "refund" the amount of tax they had saved through the exemptions unless they could show that the properties had been rented, that the tenants were required to pay the property tax and that the tax had actually been paid by the tenants. The assessor's letter did not indicate how much the potential tax payment "refund" Earls might owe related to tax levies made by the City of Chicago or any other taxing bodies for the years in question. It merely gave lump sum amounts and indicated that "refund" checks should be made payable to the Cook County treasurer's office.

¶ 15 Earls and her husband received the assessor's letter on December 13, 2010. Evidence adduced at the Election Board hearing showed that Earls' husband promptly executed documents waiving the homeowners exemption on the two properties located on Lawler Avenue and immediately made additional payments to the Cook County treasurer to make up for the reduction in taxes he and Earls had enjoyed as a result of application of the homestead exemption to those two properties. Earls testified that the payments exceeded $4,000, a figure consistent with the amounts set forth in the assessor's letter.

¶ 16 After hearing the evidence, the hearing officer made written findings of fact and conclusions of law. In the hearing officer's view, Jackson had failed to demonstrate that the additional property tax paid by Earls and her husband to the Cook County treasurer based on the Cook County assessor's challenge to the homeowner exemptions "are of the type contemplated under the Illinois Municipal Code that should bar [Earls] from being eligible to seek municipal office." He therefore recommended that the Election Board deny Jackson's objection and that Earls' name be printed on the ballot.

¶ 17 The Election Board adopted the hearing officer's recommended findings of fact and conclusions of law. In so doing, it noted that to the extent there was evidence of tax or other indebtedness, that obligation (the extra property tax) pertained to an amount Earls had to pay to Cook County, not the City of Chicago. It further observed that the hearing officer had been correct when he concluded that there was no support in the law for holding that "a debt purportedly owed to Cook County would bar a candidate from seeking office in the City of Chicago." In a written decision dated January 11, 2011, the Election Board therefore overruled Jackson's objection to Earls' candidacy, declared her nomination papers to be valid, and ordered that her name be printed on the ballot for election to the office of alderman for the 28th Ward in the municipal general election to be held February 22, 2011.

¶ 18 Jackson petitioned for judicial review (see 10 ILCS 5/10-10.1 (West 2010)), raising only the question of whether Earls was in arrears on a tax or other debt due to the City and therefore ineligible for municipal office because she and her husband had claimed homeowner exemptions to which they were not entitled and had therefore paid less in property tax than they should have. In an order entered January 27, 2011, the circuit court confirmed the decision of the Election Board to reject Jackson's objection petition and ordered that Earls' name was to appear on the ballot for the February 22 general election as a candidate for alderman for the City's 28th Ward.

¶ 19 Jackson filed her notice of appeal on February 7, 2011. Although that was just 15 days before the municipal election, the appellate court agreed to consider the appeal on an expedited basis and was able to file a written decision prior to the election. In its opinion, the appellate court reviewed the statutory scheme pertaining to taxes levied on real estate. It concluded that, "given the plain language of our statutory enactments, there is no question the amounts levied by the city of Chicago through property taxes are owing and payable to the city." 407 Ill. App. 3d at 846.

¶ 20 Taking the view that the homestead exemptions on two of the three properties owned by Earls and her husband were, in fact, unauthorized and that Earls owed back taxes as a result of having paid less in real estate tax than she should have on those parcels (id. at 842), the appellate court reasoned that Earls "was in arrears on her taxes to the city at the time she filed her nominating papers" (id. at 848) and therefore ineligible to run for alderman under section 3.1-10-5(b) of the Illinois Municipal Code (65 ILCS 5/3.1-10-5(b) (West 2010)). Accordingly, the appellate court reversed the judgment of the circuit court and set aside the Board's decision. In so doing, it ordered that Earls' name be excluded or removed from the ballot for the February 2011 municipal election. The appellate court's opinion further provided that if time constraints precluded the Board of Elections from physically removing Earls' name from the ballot, voters taking ballots in the 28th Ward were to be given a written notice that Earls had been found disqualified to run, that she was no longer a candidate, and that votes cast for her would not be counted. In addition, the appellate court directed that any votes cast for Earls on absentee ballots or early voting ballots not be counted. Id. at 848.

¶ 21 The appellate court's opinion was filed Friday, February 18, the last business day prior to the February 22 municipal election, and the court ordered that its mandate was to issue immediately. Although Earls could have requested the appellate court to recall its mandate and stay its judgment to permit her to seek review in our court (Ill. S. Ct. R. 368(c) (eff. July 1, 2006)), she did not do so. Instead she elected to proceed directly to our court with an emergency motion for a stay of the appellate court's judgment. She also asked us to grant expedited consideration of her petition for leave to appeal once it was filed. Both requests were placed on this court's regular First District motion call the next business day, February 22, which was the day of the election. (Monday, February 21, was a legal holiday.) The motion for stay was referred to the full court, making a concurrence of four members of this court necessary to dispose of it. Ill. Const. 1970, art. VI, § 3. That did not occur until the following day, after the election had concluded. At that time an order was entered denying Earls' request for a stay and for expedited consideration, but granting her leave to file a petition for leave to appeal to be considered "in due course."

¶ 22 The timing of the appellate court's judgment meant that the Election Board did not have sufficient time to remove Earls' name from the ballot or delete reference to her on its automated voting machines. In addition, there is no dispute that voters cast absentee and early voting ballots which included Earls' name. Because the appellate court's unstayed judgment directed that votes for Earls were not to be counted, and considering that voters were instructed that any votes for Earls would not be counted, we do not know how many votes Earls actually received, nor can we ascertain how many votes she might have received had the appellate court not sustained Jackson's objections. Election results disclose, however, that in the same election, a total of 8,386 votes were cast in the 28th Ward for the six mayoral candidates, the 28th Ward's combined vote total for the two candidates running for county clerk was 7,912, and 7,004 votes were received in the 28th Ward by the single unopposed candidate running for county treasurer. In the election for 28th Ward alderman, the two candidates who remained in the race after Earls was declared ineligible received a total of 6,780 votes. Of these, 5,742, or 84.69%, went to Jason Ervin, who was already serving in the post after having been appointed to fill a vacancy created when the previous 28th Ward alderman resigned. Challenger William Siegmund received just 1,038 votes. Ervin was declared the winner of the race and began a full four-year term as 28th Ward alderman in May of 2011.*fn1

¶ 23 Earls filed a timely petition for leave to appeal (Ill. S. Ct. R. 315(a) (eff. Feb. 26, 2010)) on March 11, 2011. Our court considered that petition in due course and allowed it at its May 2011 term. Following briefing, for which additional time was requested by both parties, the case was argued before our court in January of 2012 and is now before us for a decision.


¶ 25 In undertaking our review, we first consider Jackson's contention that the "clean hands" doctrine should preclude Earls from obtaining any relief from the courts. According to Jackson, Earls has "unclean hands" in that "it was the candidate's own fraudulent conduct in taking multiple homeowners exemptions that led to the termination of her candidacy, and she *** should not benefit from this wrongful conduct in this proceeding."

¶ 26 Under the "clean hands" doctrine, a party who has been guilty of misconduct, fraud, or bad faith in connection with the matter in dispute is prohibited from coming to court and asking for equitable relief. O'Brien v. Cacciatore, 227 Ill. App. 3d 836, 846 (1992). It is based on the principle that litigants should not be permitted to enlist the aid of a court of equity to further their fraudulent or unlawful purposes or take advantage of their own wrongdoing. Cole v. Guy, 183 Ill. App. 3d 768, 776 (1989); Brown v. Ryan, 338 Ill. App. 3d 864, 875 (2003). The doctrine is not favored (Brinkley v. Brinkley, 174 Ill. App. 3d 705, 714 (1988)), however, and it can have no application here. That is so for several reasons.

¶ 27 The first and most basic obstacle to Jackson's "clean hands" argument is that this is not a proceeding to obtain equitable relief. It is an appeal from a statutory challenge to a candidate's eligibility for elective office under this State's elections law. Jackson has not cited and we have not found any authority where the clean hands doctrine has been invoked to bar an appeal in an election case. Second, Earls, the party whose honesty has been questioned, was not the one who initiated judicial review of the Election Board's decision. The party who first sought the aid of the courts was Jackson, the objector. Earls is merely appealing the decision of the appellate court, which concluded that Jackson's objection should have been sustained. Jackson has not cited and we have not found any authority where the clean hands doctrine has been invoked to prevent a litigant from appealing a judgment in a case initiated by someone else. Third, though Jackson seeks to characterize Earls' conduct as "fraudulent," no finding of fraud or bad faith was ever made. Finally, fraud or bad faith in the procurement of property tax exemptions could only be relevant to Jackson's legal challenge to Earls' eligibility for municipal office if the resulting underpayment of property tax meant that Earls was in arrears in payment of tax or other indebtedness due to the municipality. As we shall explain later in this opinion, however, the additional property tax Earls and her husband paid after their exemptions were questioned was not money due to Chicago. It was money due the county. Indebtedness to the county, whether it involves fraud and dishonesty or not, does not render a candidate ineligible for municipal office under the statutory provisions on which Jackson's objections are based.

¶ 28 Jackson also asserts that Earls' appeal should be dismissed as moot. A case on appeal becomes moot where the issues presented in the trial court no longer exist because events subsequent to the filing of the appeal render it impossible for the reviewing court to grant the complaining party effectual relief. Goodman v. Ward, 241 Ill. 2d 398, 404 (2011); Cinkus v. Village of Stickney Municipal Officers Electoral Board, 228 Ill. 2d 200, 207-08 (2008). Jackson argues that effectual relief is no longer possible here because, as we have just described, the election proceeded as scheduled on February 22, 2011, and as the result of that election, someone else was selected for the office sought by Earls and has been serving in that post for more than a year.

¶ 29 Earls anticipated Jackson's mootness argument when she filed her petition for leave to appeal. Although Earls acknowledged that the election was already over, she noted in her petition that the City of Chicago was "still scheduled to have run-off elections for at least 14 various wards throughout the city on April 5, 2011," and suggested that our court could still hear and decide the case in time to permit her to participate in a runoff election in the 28th Ward on the same date. If that were not possible and the case could not be heard by April 5, 2011, Earls asked, in the alternative, that we nevertheless consider and resolve the underlying legal dispute under the public interest exception to the mootness doctrine.

¶ 30 After this court allowed Earls' petition for leave to appeal, she filed a brief which echoed this position. The brief stated that she would "welcome a special election between herself and the highest vote getter in the [February 22] municipal general election for the 28th ward" and prayed "that this court would order the [Election Board] to hold a special election for Alderman of the 28th Ward, ordering that her name be placed on the ballot."*fn2 If such relief were not possible, however, Earls asked that we nevertheless reach the merits under the public interest exception to the mootness doctrine.

¶ 31 Though the position Earls took in her brief paralleled the approach she advanced in her petition for leave to appeal, remarks made by Earls' appellate counsel at oral argument indicate that his client's position has actually changed. Earls' request for a special election is no longer contingent on the court's ability to rule prior to Chicago's April 5, 2011, runoff election. Rather, Earls asserts that a new election for 28th Ward alderman could and should be ordered even though the April 5 runoff elections have long since concluded.

¶ 32 Earls' request for a post-April 5 special election is not properly before us. That is so for two reasons. First, if Earls wanted a new election outside the normally scheduled April 5 runoffs, it was incumbent upon her to include such a request in the petition for leave to appeal. Because she failed to do so, we deem the issue to be forfeited. Buenz v. Frontline Transportation Co., 227 Ill. 2d 302, 320 (2008). Second, while Earls has presented ample argument and authority on the underlying question of why the Election Board properly rejected Jackson's objections to her nomination papers, she has offered none at all on the separate and distinct question of whether the remedy of a special election is appropriate now that the normal election cycle has concluded, the results have been certified, and the office has been filled. Again, therefore, we would deem any request for a new election to be forfeited. See Vancura v. Katris, 238 Ill. 2d 352, 370 (2010); Ill. S. Ct. R. 341(h)(7) (eff. July 1, 2008).

¶ 33 Under Supreme Court Rule 366(a)(5) (eff. Feb. 1, 1998), a reviewing court may, in its discretion, and on such terms as it deems just, "enter any judgment and make any order that ought to have been given or made, and make any other and further orders and grant any relief, including a remandment, a partial reversal, the order of a partial new trial, the entry of a remittitur, or the enforcement of a judgment, that the case may require."

This rule is frequently cited to support the familiar proposition that waiver and forfeiture rules serve as an admonition to the litigants rather than a limitation upon the jurisdiction of the reviewing court and that courts of review may sometimes override considerations of waiver or forfeiture in the interests of achieving a just result and maintaining a sound and uniform body of precedent. See, e.g., Daley v. License Appeal Comm'n, 311 Ill. App. 3d 194, 200 (1999); Hux v. Raben, 38 Ill. 2d 223, 224 (1967). The rule does not, however, nullify standard waiver and forfeiture principles. The partially dissenting justice, himself, has made the point that while our case law is permeated with the proposition that waiver and forfeiture are limitations on the parties and not on the court, that principle is not and should not be a catchall that confers upon reviewing courts unfettered authority to consider forfeited issues at will. See People v. McCarty, 223 Ill. 2d 109, 162-64 (2006) (Freeman, J., concurring in part and dissenting in part, joined by Kilbride, J.).

¶ 34 We repeat a point we recently reiterated in our unanimous opinion in People v. Givens, 237 Ill. 2d 311 (2010):

" 'In our adversary system, in both civil and criminal cases, in the first instance and on appeal, we follow the principle of party presentation. That is, we rely on the parties to frame the issues for decision and assign to courts the role of neutral arbiter of matters the parties present. *** [A]s a general rule, "[o]ur adversary system is designed around the premise that the parties know what is best for them, and are responsible for advancing the facts and arguments entitling them to relief." ' " Givens, 237 Ill. 2d at 323-24 (quoting Greenlaw v. United States, 554 U.S. 237, 243-44 (2008)). Accordingly, when cases come to us, "[w]e normally decide only questions presented by the parties." (Internal quotation marks omitted.) Givens, 237 Ill. 2d at 324 (quoting Greenlaw v. United States, 554 U.S. at 244). And " '[w]hile a reviewing court has the power to raise unbriefed issues pursuant to Supreme Court Rule 366(a)(5), we must refrain from doing so when it would have the effect of transforming this court's role from that of jurist to advocate. [Citation.] Were we to address these unbriefed issues, we would be forced to speculate as to the arguments that the parties might have presented had these issues been properly raised before this court. To engage in such speculation would only cause further injustice; thus we refrain from addressing these issues sua sponte.' " Givens, 237 Ill. 2d at 324 (quoting People v. Rodriguez, 336 Ill. App. 3d 1, 14 (2002)).

¶ 35 In arguing against our reliance on principles of waiver or forfeiture, the partial dissent makes much of the questions that were asked (or not asked) by members of this court during oral argument. We note, however, that the purpose of questioning during oral argument is simply to help the justice asking the question to better understand the controversy. Questions by the court are not and have never operated as a limitation on the grounds the court may ultimately invoke in resolving a case.

¶ 36 Wholly aside from these issues, we must also point out that, in terms of remedies, we are not writing on a clean slate. While applicability of section 3.1-10-5(b) of the Illinois Municipal Code (65 ILCS 5/3.1-10-5(b) (West 2010)) to the situation present here may present a novel question, the issue of when an election challenge becomes moot does not. It is well established under Illinois law that the conclusion of an election cycle normally moots an election contest. The author of the partial dissent made the very point in his dissent in McDunn v. Williams, 156 Ill. 2d 288 (1993), where he correctly observed that "[c]courts have repeatedly found issues concerning elections moot where the elections had already occurred. In each of these cases, the court reasoned that the occurrence of the election prevented the court from granting effective relief. (People ex rel. Lawrence v. Village of Oak Park (1934), 356 Ill. 154; People ex rel. Chancellor v. Sweitzer (1928), 329 Ill. 380.) Thus, 'when the election took place, the case became moot.' People ex rel. Knight v. Holzman (1968), 98 Ill. App. 2d 126, 127-28, citing Sokolowski v. Board of Election Commissioners (1967), 89 Ill. App. 2d 60; accord Harris v. Education Officers Electoral Board of Community Consolidated School District 110 (1990), 203 Ill. App. 3d 917; Bartos v. Chicago Board of Elections (1989), 191 Ill. App. 3d 937." McDunn v. Williams, 156 Ill. 2d at 345 (Freeman, J., dissenting).

Based on this long line of cases, the partially dissenting justice concluded that the challenge in McDunn should likewise be deemed moot. McDunn v. Williams, 156 Ill. 2d at 345-46 (Freeman, J., dissenting).*fn3

¶ 37 The democratic principles underlying our electoral system noted by the partial dissent are always implicated when questions of ballot access arise. What the partially dissenting justice has failed to do is provide some legally valid reason, based on the actual record before us, as to why this particular case should be exempt from the normal rule that ordering new elections is an extreme remedy rarely ordered by the courts of Illinois.

¶ 38 The partial dissent raises, sua sponte, the specter that the objection process was abused in this case for political purposes. We note, however, that no claim has been made that Jackson's objection and the manner in which it was processed by the Election Board did not conform, in all respects, to statutory requirements. Moreover, the evidence cited by the partial dissent consists of little more than a chronology of the steps that were followed in this case in resolving Jackson's objection.

ΒΆ 39 Unquestionably, the time between the filing deadline and the election was brief, but it is brief in every election contest. That is the way the legislature has structured the system. Under the established statutory framework, the window for bringing and resolving challenges is always small. Our experience has been that those responsible for processing those challenges in Chicago and elsewhere are well aware of the time constraints and strive to adhere to them. That was certainly the case here, as evinced by the fact that Jackson's challenge was ...

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