Corbin v. Schroeder, 2021 IL 127052

Glendale Heights holds partisan municipal elections; Election Code §10-3 (partisan) requires independent candidates to submit 5–8% (or minimum +50) of prior turnout, whereas nonpartisan municipal code requires 1%.
Village clerk Marie Schmidt (longtime local election official) misread materials during COVID-19 and told candidates the threshold was 1% (24 signatures based on 2017 turnout).
Incumbent Linda Jackson filed 50 signatures and Edward Pope filed 32; objector Matthew Corbin alleged both fell far short of §10-3 minimums (whether based on 2017 or 2018 turnout).
The Glendale Heights Municipal Officers Electoral Board found Schmidt acted in her official capacity, the candidates reasonably relied on her, and COVID-19 made reliance justified; the Board overruled the objections. Trial court and appellate court affirmed.
The Illinois Supreme Court reversed: it held Jackson-Hicks controls (§10-3 minimums are mandatory) and overruled reliance/substantial-compliance as a basis to dilute the statutory signature requirement; two justices dissented, arguing estoppel could apply under these exceptional facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory signature minima in §10-3 can be excused by reliance/estoppel on a local election official’s incorrect guidance	Corbin: §10-3 minima are mandatory under Jackson-Hicks; estoppel/substantial-compliance cannot override statute; remove candidates	Jackson/Electoral Board: Schmidt was acting in official capacity; candidates justifiably relied given COVID disruptions; estoppel preserves ballot access	Court: Reversed—Jackson-Hicks controls; minima are mandatory and cannot be diluted by reliance/estoppel in these circumstances
Whether COVID-19 and pandemic-related disruptions justify creating an equitable exception to statutory signature requirements	Corbin: pandemic does not alter clear statutory text; exceptions cannot be judicially created	Jackson/Electoral Board: pandemic was an extraordinary circumstance making candidates’ reliance reasonable and estoppel appropriate	Court: Pandemic does not authorize creating exceptions to clear statutory mandates; reliance defense insufficient to defeat §10-3

Jackson-Hicks v. East St. Louis Bd. of Election Comm’rs, 2015 IL 118929 (mandatory §10-3 signature thresholds; substantial compliance/reliance cannot substitute for statutory minima)
Merz v. Volberding, 94 Ill. App. 3d 1111 (1981) (applied estoppel/reliance to permit ballot access where local official provided incorrect signature guidance)
Vestrup v. Du Page County Election Comm’n, 335 Ill. App. 3d 156 (2002) (criticized Merz’s reliance-based approach)
Cinkus v. Village of Stickney Municipal Officers Electoral Board, 228 Ill. 2d 200 (2008) (standards for judicial review of electoral board decisions)
Patrick Engineering, Inc. v. City of Naperville, 2012 IL 113148 (estoppel against municipalities is disfavored and requires specific elements)