In re Parentage of A.C.

- Case citation and parties
In re Parentage of A.C., 2024 IL App (1st) 232052. Petitioner/Appellant: Anthony C.; Respondent/Appellee: Crystal M.; Child representative: Paul Garcia, Esq.

- Key legal issues
1. Whether the trial court properly found petitioner in indirect civil contempt for refusing to shut off/turn over electronic devices and speaking over the court.
2. Whether due process and specificity requirements for multiple contempt findings were satisfied (including adequacy of notice/hearing and absence of a transcript of the contempt hearing).
3. Legality of confiscating purported recording devices and limiting recording in court (First, Fourth, and due process claims; challenges to Ill. S. Ct. Rules 323 and 44).
4. Proper disposition of the contempt purge payment ($2,500; later allocated $1,250 to respondent for past-due child support and $1,250 to the GAL).
5. Jurisdictional/transfer issues and procedural defects (pro se appellant’s compliance with appellate standards).

- Holding / outcome
The appellate court’s judgment reads: affirmed in part, reversed in part, and dismissed in part. (The opinion upholds some of the trial-court action on reviewable grounds, reverses other aspects, and dismisses certain claims for procedural reasons.) Procedurally, the court emphasized its duty to consider jurisdiction where not addressed by appellant.

- Significant legal reasoning (high-level)
- Jurisdiction first: the court flagged Rule 304 procedural limits and the obligation to determine appealability before reaching merits; pro se litigants are held to the same standards as counsel.
- Contempt: trial judge entered ten counts of indirect civil contempt for repeated refusal to power down devices, retain recordings, and continuing to speak over the court; imposed $250 per count ($2,500) as a purge sum and ordered commitment until purge. The record lacked a certified report of proceedings for the contempt hearing, which hampered appellate review.
- Property/confiscation and recording: the trial court confiscated devices and restricted dissemination of any recordings. The appellant raised First and Fourth Amendment and state-constitutional claims and constitutional challenges to Supreme Court Rules governing courtroom recording; the opinion identifies these claims but addresses them within jurisdictional and procedural frames (including due-process specificity requirements for contempt findings).

- Practice implications (takeaways for family-law practitioners)
- Courts may impose indirect civil contempt sanctions (including commitment until purge payment) for deliberate courtroom noncompliance, including misuse of devices; ensure clear, specific orders and a full record if contempt is sought.
- When seeking contempt, obtain and preserve a certified transcript or agreed statement of proceedings — absence of a record severely limits appellate review.
- If confiscating suspected recording devices or restricting recording, contemporaneously articulate the factual basis and legal authority on the record to withstand constitutional attack.
- Be alert to Rule 304 appealability limits and ensure finality or proper interlocutory grounds are documented if immediate appeal is anticipated.
- Pro se litigants remain subject to procedural and briefing rules; courts will enforce appellate procedural standards.

(Consult the full opinion for which specific aspects the court affirmed, reversed, or dismissed.)