Background
Lenisha Robin Williams sought custody and child support for the parties’ minor child. The circuit court initially entered temporary support orders, including an order directing Gemico Tovar Childress to seek work and provide medical documentation concerning his claimed inability to work.
On November 7, 2025, after Childress did not appear, the circuit court entered a default support order requiring $411 per month in child support plus $33 for medical costs. Based on Williams’s testimony and screenshots indicating that Childress continued to work as a barber, the court imputed monthly income of $2,600 to him. Childress appealed, arguing that the court should have accounted for his SSI disability benefits.
The Court’s Holding
The appellate court affirmed. It held that Childress did not provide a record sufficient for meaningful review of the circuit court’s decision to impute income.
The November 7 order stated that the circuit court considered evidence from Williams concerning Childress’s barber work, but that evidence was absent from the appellate record. The record also lacked a transcript or bystander’s report of the hearing. Under Illinois law, those omissions required the appellate court to presume that the circuit court’s order had an adequate factual basis.
Key Takeaways
- An appellant must supply a record adequate to review the claimed error.
- When evidence considered by the trial court and a report of proceedings are missing, reviewing courts resolve doubts against the appellant.
- Documents attached to an appellate reply brief cannot be considered if they were not part of the trial-court record.
Why It Matters
The decision underscores that challenges to imputed income in child-support cases depend on a complete appellate record. Even where an obligor claims to receive SSI benefits or to be unable to work, an appellate court cannot revisit the factual basis for a support order without the evidence and hearing record before the circuit court.
The order was issued under Illinois Supreme Court Rule 23 and is nonprecedential except as Rule 23(e)(1) permits.