Ontiveroz v. Khokhar

Summary

The Illinois Supreme Court held that the circuit court lacked subject-matter jurisdiction over the election contest because the petition filed within the statutory period neither alleged that Ontiveroz voted nor included the required verification affidavits. Because election contests involving county-clerk election administration are subject to special statutory jurisdiction, the statutory prerequisites had to be strictly satisfied within 30 days and could not be cured afterward. The court therefore reversed the appellate court and affirmed the circuit court's dismissal.