The First District Appellate Court has confirmed the removal of Joseph “Joe” Severino and Rantch Isquith from the March 17, 2026 Republican primary ballot for Governor and Lieutenant Governor after they failed to meet the 5,000-signature requirement for statewide candidates. Severino v. Illinois State Board of Elections, 2026 IL App (1st) 260151-U (Feb. 20, 2026). While the case is not groundbreaking, it is instructive to future candidates.
The candidates filed nomination papers containing 6,336 signatures. An objector challenged 2,520 of them. After a records examination, the State Officers Electoral Board sustained objections to 1,588 signatures, leaving the candidates with 4,748 valid signatures—252 short of the 5,000 required under section 7-10(a) of the Election Code.
The candidates filed a timely “Rule 9” motion challenging 70 invalidated signatures but sought additional time to submit supporting evidence for nearly 200 more. Because the three-day Rule 9 evidence deadline spanned Thanksgiving, they argued good cause existed for an extension. The hearing officer denied the extension, and the Board ultimately refused to consider the late-submitted evidence.
On appeal, the candidates raised three principal arguments:
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The Board should have extended the Rule 9 deadline.
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The objector acted in bad faith when challenging signatures.
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The Lt. Governor candidate was not properly served.
The Appellate Court rejected each argument and affirmed.
Why the Appeal Failed
Two points mattered.
First, even if the court had accepted the candidates’ argument that 198 additional signatures were wrongly invalidated, they still would have fallen 54 signatures short of the 5,000 minimum. The math alone defeated the appeal.
Second, the bad faith claim collapsed under the deferential standard of review. The objector testified that his team compared petition signatures to voter registration cards before filing objections. The Board found that testimony credible. The appellate court declined to disturb those factual findings under the manifest weight standard.
As for service, counsel’s appearance on behalf of both candidates waived any personal jurisdiction objection.
The court also did not accept the constitutional ballot-access argument. Although ballot access is a significant right, the candidates could not show that enforcement of the Board’s procedural deadline changed the outcome.
Takeaways for Future Illinois Candidates
For candidates, the opinion offers practical guidance.
1. Build a Signature Cushion Well Above 5,000.
A narrow margin is not a strategy. Here, submitting 6,336 signatures produced a 1,588-signature loss after objection. A statewide campaign should anticipate aggressive challenges and collect materially more than the statutory minimum.
2. Assume Every Signature Will Be Scrutinized.
The objector’s team compared signatures and addresses before filing objections. Courts will defer to Board credibility determinations. A bad faith defense is difficult to win without concrete evidence.
3. Treat Rule 9 Deadlines as Jurisdictional in Practice.
The three-business-day window to file exceptions and supporting evidence is short. Holidays will not necessarily constitute “good cause.” Campaigns must have rapid-response teams ready to audit records examinations immediately.
4. Do the Math Before Appealing.
The appellate court emphasized that even restoring the disputed signatures would not have changed the outcome. If the numbers do not get you over 5,000, courts are unlikely to engage constitutional arguments in the abstract.
5. Preserve Service Objections Early.
An appearance and participation on the merits can waive service challenges.
Conclusion
In some ways, this case provides a useful instruction on what not to do when it comes to ballot challenges and ballot access. While the candidate has stated that he plans on appealing to the Illinois Supreme Court (which would be by filing a petition for leave to appeal), the Supreme Court may not take the case in the first place; and because early voting has already started, it’s unclear what would happen if it does take the case. This is a useful read for candidates (and their counsel) to review while working on preparing petitions to file.