Background
During their dissolution case, Anatolii Maslii sought to sell the parties’ Rolling Meadows marital home, asserting that he could no longer cover its mortgage and related costs. Nina Ivanova, who had held exclusive possession under a criminal order of protection until June 30, 2025, opposed aspects of the sale. The circuit court found that she had obstructed the process, barred her from participating in the sale, and deeded sole ownership to Maslii for purposes of completing a sale.
The court later ordered Ivanova to vacate the home and authorized the sheriff to enforce that order. On July 21, 2025, Ivanova obtained an emergency civil order of protection after alleging that Maslii entered the home. Four days later, the circuit court vacated that emergency order, finding that Ivanova had failed to disclose the eviction orders and had made false statements concerning her residence.
The Court’s Holding
The appellate court held that it lacked jurisdiction to review Ivanova’s challenges to the July 29, 2024 contempt and sale-related order and to the February 3 and July 3, 2025 eviction orders. Any interlocutory appeal under Illinois Supreme Court Rule 307, and any potentially applicable appeal under Rule 304, had to be filed within 30 days. Ivanova’s August 25, 2025 notice of appeal was untimely as to those earlier orders, and her motion to reconsider did not toll the deadline.
The appeal was timely only as to the July 25, 2025 order vacating the emergency order of protection, because the thirtieth day fell on a Sunday. The court affirmed that vacatur. It concluded that the record rebutted Ivanova’s claims that she lacked notice or a hearing, and that the incomplete record required the court to presume the circuit court’s ruling had a sufficient factual basis. The prior criminal order of protection had expired before the events underlying the emergency civil order.
Key Takeaways
- Appeals from interlocutory injunction-related orders generally must be filed within 30 days under Rule 307.
- A motion to reconsider does not extend the deadline for appealing an interlocutory order.
- An appellant bears the burden to provide a complete record; gaps are resolved against the appellant.
Why It Matters
The decision underscores that litigants must separately and promptly appeal appealable interim orders in dissolution cases. A later order repeating or enforcing an earlier directive does not necessarily reopen the deadline to challenge the original order.
The court also cautioned that pro se litigants remain responsible for verifying legal citations and warned that future filings containing invented or materially inaccurate citations may prompt sanctions.