Earlier this week, Lake County Judge Luis A. Berrones ruled that the name of Lake County Board candidate Juan Beto Ruiz (Reynoso) should not be on the ballot. The Lake County Clerk has already printed ballots with the name of candidate Ruiz on them. Ruiz is challenging incumbent Esiah Campos; and his name has been printed as Juan Beto Ruiz. But his full legal name is Juan Beto Ruiz Reynoso. Unless Ruiz appeals, any ballots cast for him will not be counted.
Under the Illinois Election Code, candidates may use given names, initials, or commonly known nicknames when filing nomination papers. But those designations must appear in addition to the candidate’s surname, which the statute treats as the essential element of the candidate’s name for ballot purposes.
Illinois courts have interpreted that requirement strictly. In Shannon-DiCianni v. Du Page County Officers Electoral Board, the appellate court upheld removing a candidate from the ballot after she filed nomination papers using a hyphenated name that combined her nickname with her legal surname. Shannon-DiCianni v. Du Page Cnty. Officers Electoral Bd., 2020 IL App (2d) 200027, 167 N.E.3d 1142. Although the candidate argued that the hyphen simply identified a nickname, the court concluded that voters would reasonably read the hyphenated form as a double surname, which created a name that was not her legal surname. Because the Election Code allows nicknames only in addition to a surname; and for her, the designation was part of, not in addition to, her surname. Id.
In Shannon-DiCianni, the Court also noted that the combination could be used to present the candidate as potentially being of multiple heritages. Id. at 21. And that the presentation of the candidate’s name in this way ultimately presented a false surname to the public. Id.
Illinois courts sometimes apply a “substantial compliance” approach when technical defects in nomination papers do not affect the integrity of the election process. But naming requirements tend to receive closer scrutiny because they directly affect how voters identify candidates. When nomination papers present a surname that differs from the candidate’s legal surname, courts have treated that issue as a statutory violation rather than a minor technical defect.
The recent Lake County decision appears consistent with that line of cases. It serves as a reminder that Illinois election challenges often turn on detailed statutory requirements — and that even small variations in how a candidate’s name appears on nomination papers can determine whether the candidate ultimately appears on the ballot.