Background
Christopher F. filed a 2024 parentage and parental-responsibility action concerning Cali F. Christina B., Cali’s maternal grandmother, had been caring for Cali by agreement and was later appointed her plenary guardian. Orders gave Christina day-to-day, medical, educational, and financial authority, while Christopher received visitation.
After the parties entered an agreed visitation order in February 2026, Christina petitioned for a rule to show cause and a finding of indirect civil contempt. She alleged that Christopher violated the order when he refused to disclose the name and location of a stylist who had braided Cali’s hair. Following a hearing at which the parties testified, the Randolph County circuit court denied the petition. Christina appealed without counsel.
The Court’s Holding
The Illinois Appellate Court, Fifth District, affirmed. The court held that Christina had not supplied an adequate appellate record to establish error in the denial of her contempt petition.
The docket showed that the circuit court held an evidentiary hearing and heard testimony, but the appellate record contained neither a report of proceedings nor an authorized substitute, such as a bystander’s report or agreed statement of facts. Because the appellant bears the burden to provide a sufficient record, the court presumed the circuit court acted correctly and declined to speculate about the claimed errors.
Key Takeaways
- An appellant challenging an evidentiary ruling or finding must provide a transcript or an acceptable substitute for the hearing record.
- When the appellate record is incomplete, Illinois reviewing courts resolve doubts in favor of the circuit court’s judgment.
- An appellee’s failure to file a brief does not require automatic reversal.
Why It Matters
The decision underscores a recurring appellate-procedure rule: even potentially substantive family-law disputes may fail on appeal if the record does not permit review of what occurred at the hearing. Litigants proceeding pro se remain responsible for furnishing that record.
This was a nonprecedential Rule 23 order, usable only in the limited circumstances Illinois Supreme Court Rule 23(e)(1) permits.