Background
Carbondale Limited Partnership, doing business as The Fields Apartments, filed an eviction action against tenant Roosevelt Holley in January 2025. The parties entered an agreed settlement order requiring Holley to vacate and return the keys by March 15, 2025. If he complied, the landlord would not oppose sealing the eviction case.
Holley later sought to vacate and cancel the settlement agreement, asserting that he had been forced to sign it to avoid an eviction record and alleging sexual misconduct. The Jackson County circuit court denied his motions. Holley, acting pro se, appealed the April 3, 2025, denial of his motion to cancel the settlement agreement.
The Court’s Holding
The appellate court affirmed. Holley did not provide an adequate record to establish circuit-court error because the appellate record contained neither a report of proceedings nor a bystander’s report for the relevant hearings.
The court also found that Holley’s appellate brief did not comply with Illinois Supreme Court Rule 341. It lacked both a statement of facts and an argument supported by record citations and legal authority. With no adequate record or compliant argument showing error, the court presumed that the circuit court acted correctly.
Key Takeaways
- An appellant bears the burden of providing a record sufficient to support the claimed error.
- Absent a transcript or acceptable substitute, reviewing courts presume the trial court’s ruling was proper.
- Pro se litigants must still comply with appellate briefing rules.
Why It Matters
The decision underscores that challenges to settlement agreements require a developed appellate record and a properly supported appellate argument. Allegations made in a motion, without a record of the hearing or a compliant brief explaining reversible error, will not overcome the presumption favoring the trial court’s ruling.
The order was issued under Illinois Supreme Court Rule 23 and is nonprecedential except as permitted by Rule 23(e)(1).