The Resolution of Election Disputes: Legal Principles that Control Election Challenges At the board’s hearing there was testimony that the petition contained forged signatures of dead people, that voters were misled as to the nature of the petition they were signing, that some of the forms with signatures did not set out the purpose of the form, that the names of fictitious people were on the petition, that wrong addresses or misspelled names were on the forms, and that some newly registered voters were told that signing the petition was part of the voter registration process (500 of 700 newly registered voters signed the form). As to all of this information, the court in Stapleton said, Whether or not all of this comprised sufficient evidence for the Board to conclude, as some members apparently did, that there was pervasive fraud sufficient to invalidate the entire petition…there was substantial evidence upon which the Board majority could reasonably conclude, as it did, that there were insufficient valid signatures to require a recall election… At 4 (emphasis supplied). …The Court’s role is merely to insure that the Board reasonably complied with the legal requirements of fair procedure and of the…applicable laws… The Court finds that the Board, under the circumstances and in the limited time it had available, dealt as fairly as it could with the difficult and emotion-provoking issues thrust upon it, and that the Board’s decision not to certify the mayoral recall petition was supported by substantial evidence, was not contrary to law, and was not arbitrary or capricious. At 5 (emphasis supplied). D. On review, a lower court’s findings can be reversed based on a new interpretation of the law. The standard that administrative or judicial findings of fact will not be reversed unless they are against the manifest weight of the evidence is very hard to meet. But it is not impossible. Sometimes, a reviewing court may appear to unfairly decide that an administrative board or lower court’s finding was not supported by the evidence because the reviewing court adopted a new interpretation of the law. That is what happened in Keating v. Iozzo, 508 N.E.2d 503 (Ill. App. 1987), which arose when Mike Iozzo was a candidate for village trustee in Villa Park, Illinois. He wanted to challenge the sufficiency of the signatures on nominating papers that three other candidates—Dennis Keating, Emil “Bud” Vittorio and Larry Dean (ne Mieszcak)—had filed to run as village trustee. Objections to nominating papers had to be filed with the village clerk by February 2, 1987. At 10:50 a.m. that day the village clerk called all of the candidates, including Mr. Iozzo, and told them she would be in the office only until noon that day. Mr. Iozzo told her he would be filing his objections by three o’clock. When he arrived at city hall shortly after three o’clock, the clerk’s office was closed and there was no deputy clerk there, so he did not file his objections until the next day, February 3. The village electoral board decided that Mr. Iozzo’s inability to file his objections was the clerk’s fault because her office was supposed to be open from 9 a.m. to 5 p.m. The board found that Mr. Iozzo’s objections were timely filed, and because they were timely filed the board had jurisdiction to hear evidence about the sufficiency of the signatures on the other candidates’ nominating petitions. The board found that the other candidates’ nominating signatures were insufficient and took their names off of the ballot. Candidates Keating, Vittorio and Mieszcak filed a lawsuit against Mr. Iozzo, the electoral board and others challenging the board’s decision. The trial court reversed the electoral board’s finding that the ob- 124