Filed Date: Dec. 20, 2006
Closed Date: June 18, 2007
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This is a case concerning alleged vote dilution in Putnam County.
On December 20, 2006, seven residents of Putnam County filed suit against the Putnam County Community School District challenging the election of the Board of Education of Putnam County Community District #535. In Putnam County, only three of seven board members could be elected from a district that contained a majority of the population. In their complaint, plaintiffs alleged 105 ILCS 5/11 A-8, succeeded by 105 ILCS 5/9, violated the Constitution of the United States and the State of Illinois insofar as it provided that residents of a township containing a majority of the population in a school district could not vote for a majority of the members of the board of education in a school district. Plaintiffs, represented by private counsel, sought declaratory relief because they contended their votes were diluted, and injunctive relief to prevent the Board of Education from conducting business. In addition, plaintiffs requested attorney's fees.
Defendant removed the case to the Central District of Illinois on January 12, 2007 in light of the federal questions presented and it was assigned to District Judge Joe B. McDade. On February 14, 2007, Defendant filed a motion to dismiss and stay proceedings to afford the Illinois Attorney General an opportunity to intervene. The motion to dismiss was based on prior caselaw upholding constitutional challenges to election schemes that candidates be residents of certain districts that did not contain equal numbers of people.
After plaintiffs filed a late response on April 12, 2007, the Court issued an order on June 18, 2007 denying the stay and dismissing the Complaint. Defendant's motion to stay was denied as moot as the Attorney General's office declined to intervene. The Court held that plaintiffs' equal protection claim of diluted votes failed to state a claim because the scheme described by plaintiffs aligned with cases cited by Defendant in its motion and which were previously upheld. Notably, where (1) board members represent the entire county, not just the district in which they reside, and (2) those members are elected in an at-large format instead of the residency of voters––the scheme was not unconstitutional. Similarly, plaintiffs' claim that the most popular candidate could be denied a seat simply because the district had reached its maximum number of candidates, thereby depriving plaintiffs of a potential candidate, was denied. The Court reasoned Putnam County's scheme fostered geographic diversity and without invidious discrimination, and as such, plaintiffs failed to state a claim.
Summary Authors
Trevor Zeiler (12/15/2023)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/12272837/parties/moore-v-putnam-county-community-school-district-535/
McDade, Joe Billy (Illinois)
Grivetti, John A (Illinois)
Delort, Mathias William (Illinois)
Jr, Everett E (Illinois)
Katz, Heidi A (Illinois)
See docket on RECAP: https://www.courtlistener.com/docket/12272837/moore-v-putnam-county-community-school-district-535/
Last updated March 9, 2024, 3 a.m.
State / Territory: Illinois
Case Type(s):
Key Dates
Filing Date: Dec. 20, 2006
Closing Date: June 18, 2007
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Seven residents challenging the election of the Putnam County Community School District's Board of Education.
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Attorney General (Putnam), County
Defendant Type(s):
Case Details
Causes of Action:
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
General/Misc.:
Voting: