Background
Laurie B. and Nathan S., who never married, are the parents of J.A.B., born in 2015. A Michigan judgment of affiliation was entered in 2016, and the Michigan orders were enrolled in Sangamon County, Illinois, in 2021. An agreed Illinois order entered in April 2022 gave the parents joint decision-making authority and established parenting time.
In May 2025, Nathan sought to modify parenting time and parental responsibilities, alleging substantial changes in circumstances. Following three days of hearings, the circuit court found modification necessary for the child’s best interests. It awarded Nathan sole decision-making authority over education, medical care, religion, and extracurricular activities; directed that J.A.B. reside with him; and gave Laurie alternating-weekend parenting time. The court later denied Laurie’s reconsideration motions.
The Court’s Holding
The Illinois Appellate Court, Fourth District, affirmed. Laurie argued that the modification order was against the manifest weight of the evidence and that the circuit court wrongly denied reconsideration.
But Laurie did not provide a report of proceedings, bystander’s report, or agreed statement of facts for the three evidentiary hearings. Because an appellant must supply a sufficiently complete record to support claimed error, the appellate court presumed the circuit court’s order conformed with the law and had an adequate factual basis. Without a record of the testimony, it could not review Laurie’s evidentiary or reconsideration claims.
Key Takeaways
- An appellant bears the burden of providing a record adequate for appellate review.
- Without a transcript or permissible substitute, reviewing courts presume the trial court acted correctly.
- The court affirmed the order giving Nathan primary residential care and sole decision-making authority on the listed major issues.
Why It Matters
The decision underscores that merits challenges in parenting-time and parental-responsibility appeals can fail at the threshold when the appellant omits the evidentiary record. Detailed assertions about hearing testimony in an appellate brief cannot replace a report of proceedings or another authorized record substitute.