Background
HB2 Alternative Investments sought possession of a Chicago property after acquiring it through a judicial-sale deed issued in a separate foreclosure case. HB2 alleged that Lachelle Bowers, Kelly Bowers, and unknown occupants remained in possession despite a demand for possession.
Bowers, acting pro se, filed several motions seeking stays, dismissal, and reconsideration, challenging HB2’s authority and standing to evict her. The circuit court denied or struck the motions and, after a November 2025 bench trial, entered an eviction order for HB2. Bowers appealed.
The Court’s Holding
The Illinois Appellate Court affirmed. Bowers did not provide a report of proceedings, bystander’s report, agreed statement of facts, or other acceptable record of the trial or relevant motion hearings.
Without an adequate record, the court could not assess her claims that the circuit court arbitrarily denied motions, failed to conduct meaningful hearings, or acted with bias and made improper factual findings. The appellate court therefore presumed the circuit court acted lawfully and on a sufficient factual basis.
Key Takeaways
- An appellant bears the burden to provide a complete record adequate for appellate review.
- Uncertified materials attached to an appellate brief cannot supplement the record.
- Pro se litigants must comply with the same appellate rules as represented parties.
Why It Matters
The decision underscores that appellate challenges to hearing procedures, factual findings, and judicial impartiality generally cannot succeed without a certified record showing what occurred below. When the record is incomplete, reviewing courts resolve doubts in favor of the judgment.