Background
Tameika Williams petitioned for emergency and plenary orders of protection against her sibling, Sherrica Jimerson. Williams alleged that Jimerson sent text messages to Williams and their grandmother threatening to break into the grandmother’s house, called Williams “the devil and a witch” and a “demon,” and sent videos showing Jimerson breaking into the house. Williams separately alleged that Jimerson told their grandmother she would kill Williams.
After initially denying emergency relief, the circuit court later reconsidered and entered an emergency order of protection, which it extended while the parties attempted mediation. Following a May 2, 2025 hearing, the court entered a plenary order effective until May 1, 2026, barring Jimerson from abusing, harassing, stalking, interfering with, or contacting Williams and granting Williams exclusive possession of the residence. Jimerson’s motion to reconsider was denied, and she appealed without providing a transcript, bystander’s report, or agreed statement of facts from the hearing.
The Court’s Holding
The appellate court affirmed because Jimerson did not supply a sufficiently complete record to permit review of her claims. Without a record of the May 2 hearing, the court could not determine what testimony, evidence, or exhibits were admitted or excluded, what arguments the parties made, or why the circuit court entered the plenary order.
The court also could not assess Jimerson’s allegations of evidentiary and procedural errors or a hostile courtroom at other hearings. Under established appellate principles, doubts arising from an incomplete record are resolved against the appellant, and the reviewing court presumes that the circuit court’s order conformed with the law and had a sufficient factual basis. Although Jimerson’s brief also violated multiple briefing requirements, the court declined to dismiss the appeal on that ground and instead affirmed based on the inadequate record.
Key Takeaways
- An appellant must provide a record sufficiently complete to support each claimed error.
- When no hearing transcript or acceptable substitute is supplied, the reviewing court presumes the trial court’s judgment was lawful and factually supported.
- Self-represented litigants must follow the same appellate briefing and record-preservation rules as attorneys.
Why It Matters
The order underscores that appellate review depends on the contents of the record, not an appellant’s description of what occurred below. Challenges to factual findings, evidentiary rulings, courtroom conduct, or hearing procedures generally cannot succeed when the relevant proceedings have not been preserved through a transcript or an authorized substitute.
The disposition also illustrates that a court may reach the record issue despite serious defects in a pro se brief. This order was filed under Illinois Supreme Court Rule 23 and is nonprecedential except in the limited circumstances permitted by Rule 23(e)(1).