In re Marriage of Thompson

- Case citation and parties
In re Marriage of Thompson, No. 1-25-0562, 2025 IL App (1st) 250562-U (1st Dist. Aug. 25, 2025). Petitioner-Appellant: Rashida Thompson. Respondent-Appellee: Christopher Thompson.

- Key legal issues
1. Whether the appellate court had jurisdiction to review post‑dissolution orders that (a) restricted a parent’s telephone/video contact with the children during the other parent’s parenting time and (b) prohibited the parent from contacting police to perform wellness checks (with threatened fines for violations).
2. Procedural adequacy of appellant’s appeal (timeliness; whether leave to appeal an interlocutory custody-related order was sought; adequacy of the appellate record).

- Holding / outcome
The First District dismissed the appeal for lack of appellate jurisdiction.

- Significant legal reasoning (concise)
The court determined that the order being appealed was not a proper basis for appellate review in the posture presented. The challenged rulings were post‑dissolution/interlocutory family‑court orders governing parenting time and conduct; the appellant did not obtain or demonstrate an appealable basis (such as timely appeal from a final judgment or leave to pursue an interlocutory appeal under the custody/visitation interlocutory‑appeal rule). The panel emphasized procedural deficiencies in the record (no trial transcripts) that impeded appellate review of factual or discretionary determinations. Because the procedural requirements for appellate jurisdiction were not met, the court did not reach the merits and dismissed the appeal.

- Practice implications for family law practitioners
- Timeliness and procedural posture are critical: appeals from custody/parenting‑time orders often require either (a) a timely appeal from a final judgment or (b) leave to appeal from specified interlocutory custody orders (follow Illinois Supreme Court rules and local practice). Failure to follow the correct appellate vehicle will result in dismissal for lack of jurisdiction.
- Preserve and build an appellate record: secure and include transcripts (or obtain agreed statements) for any hearing likely to be appealed; absence of transcripts can foreclose meaningful review.
- When seeking or defending restrictive parenting-time conditions or sanctions (e.g., prohibitions on wellness calls or threats of fines), obtain written findings of fact and legal bases in the trial court to create an appealable record.
- Consider immediate motions (reconsideration/clarification) or petitions for interlocutory review when orders raise substantial rights that will be mooted or merged by later proceedings.