Background
Jack Walter sought emergency and plenary orders of protection against Haili Williams, his former girlfriend and the mother of their child. Walter alleged that Williams repeatedly called him, police, the child’s school, and Walter’s church, making accusations that Walter was harming the child. An emergency order issued in November 2025 and was extended pending a February 2026 hearing.
At that hearing, Walter presented evidence of numerous calls and police welfare checks, including late-night visits to his home. Williams, appearing without counsel, admitted making more than 40 police calls in about a month—46 calls in a nine-day November span—and contacting people associated with Walter and the child. She said she acted to protect the child but offered no evidence supporting her abuse allegations. The circuit court entered a two-year plenary order, barring her from contact with Walter and the child and denying visitation.
The Court’s Holding
The appellate court affirmed. It held that Williams received procedural due process because she appeared and participated fully in the hearing, had no right to appointed counsel in this proceeding, and did not seek a continuance to retain counsel. The trial court properly excluded her character letters as hearsay; their authors were unavailable for cross-examination, and the letters did not establish a material fact relevant to the alleged harassment.
The court also concluded that the circuit court made the required statutory findings and that its decision was not against the manifest weight of the evidence. Williams’s admitted calls and reports caused repeated police involvement and emotional harm to Walter and the child, while her allegations of abuse lacked support. Finally, the appellate court found that the trial judge’s comments did not overcome the presumption of judicial impartiality or demonstrate personal hostility or bias.
Key Takeaways
- A self-represented respondent in an Illinois order-of-protection proceeding must follow ordinary evidentiary and procedural rules.
- Unverified character letters from absent authors may be excluded as hearsay.
- Repeated unsupported reports to police and others can support a finding of harassment and restrictions on parenting time.
Why It Matters
The decision illustrates that protective-order proceedings may restrict a parent’s contact with a child when supported by findings of harassment and the child’s best interests, even though the order does not permanently terminate parental rights.
It also underscores that an appellate challenge based on lack of counsel or alleged judicial bias requires a concrete procedural deprivation or evidence of actual prejudice, not merely dissatisfaction with evidentiary rulings or the trial court’s assessment of the evidence.