State ex rel. Ahlgrimm v. State Elections Board

In State ex rel. Ahlgrimm v. State Elections Board, 82 Wis. 2d 585, 263 N.W.2d 152, 157 (WI 1978), a candidate for a judicial election filed his petition on time, but not in the proper place. The Wisconsin State Elections Board refused to certify Ahlgrimm as a candidate. The Wisconsin Court held that filing a nomination petition in the wrong location was not substantial compliance with a filing statute. "The time and place of filing nomination papers cannot be separated. In order to be timely, the papers must be filed in the proper place. If the papers are initially filed in the wrong place, the error must be corrected and the papers filed in the right place within the filing deadline. Consistent with our earlier opinions . . . we view the statute governing the time of filing and the statute governing the place of filing nomination papers . . . to be mandatory. Failure to timely file the papers in the proper place prevents the candidate's name from being placed on the ballot." (Id. at 157.)