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SHARON ANN MERONI, )
One West Surrey Lane )
Barrington Hills, IL 60010 )
224-357-8366 Fax )
Illinois State Board of Elections: )
Jesse R. Smart (Chairman) )
Charles W. Scholz (Vice Chairman) )
William M. McGuffage )
Harold D. Byers )
Betty J. Coffrin )
Ernest L. Gowen )
Bryan A. Schneider )
Casandra B. Watson )
Rupert T. Borgsmiller (Executive Director) )
Steve Sandvoss (General Counsel) )
TITLE III HAVA COMPLAINT
Now comes SHARON ANN MERONI (hereinafter referred to as the “Complainant”), and
for her Complaint states as follows:
1. The Complainant resides at One Surrey Lane, Village of Barrington Hills, in the
County of McHenry in the State of Illinois, and as of the date of filing of this complaint is duly
qualified, registered and a legal voter at such address.
2. The Complainant's interest in filing this Petition is that of a voter desirous that the
federal and state laws governing the administration of elections are properly complied with.
PROVISION OF THE ACT VIOLATED
SEC. 402. 42 USC 15512.ESTABLISHMENT OF STATE-BASED ADMINISTRATIVE
COMPLAINT PROCEDURES TO REMEDY GRIEVANCES.
(B) Under the procedures, any person who believes that there is a violation of any provision of
title III (including a violation which has occurred, is occurring, or is about to occur) may file a
ILLINOIS ADMINISTRATIVE RULE IN VIOLAION OF SEC 402.42 (B)
TITLE 26: ELECTIONS CHAPTER I: STATE BOARD OF ELECTIONS -PART 150
ADMINISTRATIVE COMPLAINT PROCEDURES FOR VIOLATIONS OF TITLE III OF
HAVA SECTION 150.15 FILING OF A COMPLAINT
Section 150.15 Filing of a Complaint:
Any person who believes that a violation of any provision of Title III of the Act has occurred, is
occurring or is about to occur may file a complaint with the State Board of Elections. The
complaint must be filed no later than 90 days after the occurrence of the violation or 90 days
after the federal election in connection with which the violation occurred, whatever date is later.
Any complaint filed under this Section must allege a violation of Title III of the Act, state
specifically the nature of the violation and be sufficiently grounded in fact and in law. In
addition, the complaint must state whether the complainant desires a hearing on the record before
the State Board of Elections.
TIME AND PLACE
This timing of this complaint is that a violation of Title III has occurred, is occurring, and will
continue to occur until the alleged rule is stricken. This violation is a result of Illinois
Administrative Rules, taking place in and impacting the entire State of Illinois and all of her
NATURE OF THE COMPLAINT: STATEMENT OF FACTS
1. The Complainant asserts she is restricted from filing complaints about HAVA Title III
violations by this rule.
2. The Complainant has other HAVA Title III complaints that she wishes to file against the
Illinois State Board of Elections..
3. The Complainant asserts that Sec 402 (B) allows her the right to file a HAVA Title III
complaint outside of the 90 day restive clause found in Illinois Administrative Rule Title 26:
Elections Chapter I Part 150.15. This Rule states: “The complaint must be filed no later than 90
days after the occurrence of the violation or 90 days after the federal election in connection with
which the violation occurred, whatever date is later.”
4. Illinois Administrative Code 150.15 has a restrictive clause which mandates HAVA Title III
complaints must be filed 90 days after an occurrence or 90 days after the federal election in
connection with which the violation occurred. The Complainant alleges that SEC. 402. 42 USC
15512 (B) permits “Under the procedures, any person who believes that there is a violation of
any provision of title III (including a violation which has occurred, is occurring, or is about to
occur) may file a complaint”.
5. The Complainant’s rights as permitted by Title III are violated by this Rule.
Therefore the Complainant desires a hearing on the record before the State Board of Elections.
The Complainant does not relinquish her right for this matter to go through Alternative Dispute
Therefore the Complainant requests that the current Illinois Administrative Rule Title 26:
Elections Chapter I Part 150.15 be stricken.
Therefore the Complainant requests the Board shall, in its order, take whatever action it is
authorized under federal or State law and deems appropriate under the circumstances to correct
the matter complained of and shall provide a timeframe in which its order must be complied with
and the consequences of failure to comply.
Therefore the Complainant requests that the Illinois State Board of Elections responds to her
other HAVA Title III objection.
Therefore the Complainant shall receive all other benefits, rights, and relief afforded to her
because of this violation of her rights.
"I declare that this complaint (including any accompanying exhibits and statements) has been
examined by me and to the best of my knowledge and belief is a true and correct complaint as
required by Section 402 of the Help America Vote Act."
Sharon Ann Meroni
Signed and sworn to (or affirmed) by Sharon Meroni
before me on this day of September 15
Signature of Notary Public
(SEAL OF NOTARY)