In re Marriage of Lee, 2025 IL App (1st) 241564-U

Summary

Case Summary: In re Marriage of Lee, 2025 IL App (1st) 241564-U - A sovereign citizen's divorce appeal crumbled spectacularly when Moorish Science Temple filings and certified mail receipts—submitted by an unlicensed "representative"—were deemed legal nullities, leaving no valid record for the Illinois appellate court to review. In re Marriage of Lee delivers a brutal reminder that missing transcripts, Rule 341 violations, and fringe jurisdictional theories don't just fail—they guarantee forfeiture of every argument before the court even reaches the merits.

The opposing counsel is already on the back foot—because they assumed their client could stall a divorce case with Moorish Science Temple filings and certified mail receipts that never touched the circuit court record. The First District just reminded everyone what happens when you bring sovereign citizen theater to a Cook County courtroom: you lose, and you lose on appeal too.

In re Marriage of Lee, 2025 IL App (1st) 241564-U, is a masterclass in how not to handle a dissolution case—and a warning shot for every family law practitioner who thinks the record will somehow assemble itself.

The Facts: A Default Judgment and a Disappearing Respondent

Steven Jermaine Lee (appearing pro se and styling himself "Bro. S. Lee Bey") failed to appear at the July 3, 2024 trial. The court found him in default. Dissolution was granted to Petitioner Antoinette Jameica Lee.

What followed was a parade of post-judgment filings—some submitted by a "Prophet Noble Drew Ali" representative of the Moorish Science Temple—challenging jurisdiction, attaching certified mail receipts, and invoking religious-nation identity theories. The trial court treated these filings as nullities. The appellate court affirmed.

The result was never in doubt once you understand Illinois appellate procedure.

The Three Fatal Errors That Sank This Appeal

1. No Transcript, No Review

The appellant provided no report of proceedings from the dissolution trial. No transcript. No bystander's report under Supreme Court Rule 323(c). No agreed statement under Rule 323(d). Nothing.

Under Foutch v. O'Bryant, 99 Ill. 2d 389 (1984), when the appellate record is incomplete, the reviewing court presumes the trial court acted correctly. This is not a technicality—it is the foundation of Illinois appellate review. If you cannot show the court what happened below, you cannot argue the court got it wrong.

The lesson: Order your transcripts. File your Rule 323 substitutes. Do it immediately after the hearing you intend to challenge. Waiting until the appeal is filed is too late.

2. Rule 341 Violations Forfeited Every Argument

The appellant's brief failed to comply with Illinois Supreme Court Rule 341's requirements for cohesive legal argument. Instead of citations to the record and applicable authority, the court received documents that were never part of the circuit court file.

Appellate courts are not obligated to construct arguments for litigants. When a brief is noncompliant, arguments are forfeited. Period.

The lesson: Rule 341 compliance is not optional. Cite the record. Cite authority. Structure your argument. If you cannot do this, you are not ready to file an appeal.

3. Non-Lawyer Filings Are Nullities

Here is where the case becomes instructive for practitioners dealing with unusual opposing parties. Multiple filings were submitted to the trial court by a non-attorney purporting to represent the respondent—specifically, a representative of the Moorish Science Temple.

Under Applebaum v. Rush University Medical Center, 231 Ill. 2d 429 (2008), and related authority, a non-lawyer cannot represent another person's interests in Illinois courts. Such filings are nullities. They do not toll deadlines. They do not preserve issues. They do not create appellate record entries.

The certified mail receipts attached to the appellate brief? Not part of the circuit court record. Cannot be considered on appeal.

The lesson: If your opposing party or their "representative" is filing documents signed by someone who is not the party or a licensed attorney, those documents are worthless. Do not let them distract you from prosecuting or defending your case.

Strategic Implications for High-Stakes Dissolution Practice

Document Everything—Because They Will Not

When you are dealing with a respondent who fails to appear, invokes fringe legal theories, or has "representatives" filing on their behalf, your documentation becomes the entire case. Ensure your service proofs are bulletproof. Confirm appearances and withdrawals of counsel are on the record. Request court reporters for every substantive hearing.

When the other side eventually claims they were denied due process, your meticulous record will be the only thing that matters.

Default Judgments Are Powerful—If You Protect Them

The trial court granted dissolution after finding respondent in default. That judgment stood because petitioner's counsel (or petitioner, if pro se) ensured the procedural requirements were met. Default judgments in dissolution cases can be challenged—but only if the challenging party has something to challenge with.

In Lee, the respondent had nothing. No transcript. No compliant brief. No valid filings. The judgment was affirmed on the basis that there was simply nothing to review.

Sovereign Citizen and Religious-Nation Arguments Do Not Work

Illinois courts have consistently rejected jurisdictional challenges based on Moorish Science Temple affiliation, sovereign citizen theories, and similar claims. These arguments do not divest courts of jurisdiction. They do not excuse failure to appear. They do not substitute for proper appellate procedure.

If your opposing party begins invoking these theories, do not engage on the merits. Simply proceed with your case, document their failures to comply with court orders, and let the record speak for itself.

The Tech-Law Intersection You Cannot Ignore

In high-net-worth dissolution cases, the respondent who disappears from court often leaves a digital trail that does not disappear. Email metadata, cloud storage access logs, financial platform login records—these become critical when the other side claims they "never received notice" or "were not properly served."

Cyber negligence is leverage in discovery. If your opposing party claims ignorance of court proceedings while their digital footprint shows active engagement with financial accounts, social media, or business operations, that inconsistency is ammunition.

Preserve electronic evidence early. Issue litigation holds. Subpoena platform records before they are deleted. The party who controls the digital record controls the narrative.

What This Case Teaches About Appellate Strategy

In re Marriage of Lee is an unpublished decision, meaning it cannot be cited as precedent. But it illustrates principles that are bedrock Illinois law:


Foutch v. O'Bryant controls when the record is incomplete.
Rule 341 compliance is mandatory, not aspirational.
Applebaum and related authority bar non-lawyers from representing others.
Documents outside the circuit court record cannot be considered on appeal.


These are not obscure procedural traps. They are the rules of engagement. Ignore them and your appeal dies on arrival.

Your Next Move

If you are facing a dissolution case involving a non-compliant opposing party, fringe legal theories, or the threat of an appeal built on procedural quicksand, you need counsel who understands both the courtroom and the digital battlefield.

The opposition is already losing. The question is whether you are positioned to capitalize on their failures.

Book a consultation now. We do not wait for the other side to figure out what they did wrong.

Full Opinion (PDF): Download the full opinion

Written by Jonathan D. Steele

Chicago divorce attorney with cybersecurity certifications (Security+, CEH, ISC2). Illinois Super Lawyers Rising Star 2016-2025.

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