Background
Jennifer Putibet petitioned for a stalking no-contact order against Kendra Taylor in August 2024. Putibet alleged that Taylor tried to assault her at a bar in May 2024, then struck her at Hillside Bowl in August and later attempted to enter Putibet’s home uninvited.
The circuit court entered an emergency order and later, on February 13, 2025, a plenary stalking no-contact order. The plenary order barred Taylor from coming within 100 feet of Putibet’s residence and Hillside Bowl and prohibited contact by any means. Taylor appealed pro se, asserting that the trial court had not accepted or considered her documents.
The Court’s Holding
The appellate court affirmed. Taylor did not provide a report of proceedings from the hearing at which the circuit court made its findings, nor did she provide an acceptable substitute such as a bystander’s report or agreed statement of facts.
Without that record, the court could not determine what evidence or arguments the circuit court considered, whether documents were admitted or excluded, or whether the order was against the manifest weight of the evidence. It therefore presumed the trial court’s order conformed to law and had a sufficient factual basis. The court also declined to consider materials Taylor attached to her appellate brief because they were not part of the certified record.
Key Takeaways
- An appellant must supply a sufficiently complete appellate record to support a claimed error.
- Absent a hearing transcript or authorized substitute, reviewing courts presume the trial court acted properly.
- Materials attached to an appellate brief cannot supplement the certified record.
Why It Matters
The decision underscores that procedural record requirements can be dispositive in appeals from stalking no-contact orders. A pro se appellant is held to the same appellate rules as a represented party.
This Rule 23 order is nonprecedential except in the limited circumstances permitted by Illinois Supreme Court Rule 23(e)(1).