In re Marriage of Maslii
Nonprecedential Rule 23(b) written order. Because it was entered on or after January 1, 2021, it may be cited for persuasive purposes under Rule 23(e)(1), but it is not binding precedent. Status is based on the stored -U public-domain citation; verify the official disposition and later docket history.
Case Analysis
Overview
In this pro se appeal from a Cook County dissolution case, the appellate court affirmed the circuit court's July 25, 2025 order vacating an emergency order of protection obtained by the wife, and dismissed the remainder of the appeal for lack of jurisdiction because the earlier contempt, eviction, and eviction-enforcement orders were not appealed within 30 days. The court also issued an extended warning about generative AI "hallucinated" citations in a pro se brief, declining to sanction this time but promising a rule to show cause for any future offending filings.
Key Facts
Maslii petitioned for dissolution in April 2022; the parties owned a marital home in Rolling Meadows.
Ivanova obtained a plenary criminal order of protection on January 30, 2023 giving her exclusive possession of the marital home, extended through June 30, 2025.
The court ordered the home sold in September 2023 after Maslii showed he could no longer carry the mortgage, taxes, and expenses; a listing agent was appointed.
Maslii filed repeated motions alleging Ivanova obstructed the sale (blocking showings, refusing to sign documents, altering terms); the listing agent was separately reprimanded for failing to disclose at least one offer.
On July 29, 2024, the court found Ivanova in contempt, barred her from involvement in the sale, and entered a judicial deed vesting the home in Maslii for sale purposes under section 501 injunctive relief.
The court entered an eviction order February 3, 2025 and an enforcement order July 3, 2025 directing the Sheriff to remove her.
On July 21, 2025 (after the criminal order of protection had expired and an extension was denied), Ivanova obtained an emergency civil order of protection alleging Maslii entered the home; the court vacated it July 25, 2025, finding she had lied about her residence and concealed the eviction orders.
Notice of appeal filed August 25, 2025.
Procedural History
Appeal from the Circuit Court of Cook County, No. 2022 D 003121 (Hon. Patricia M. Fallon). Ivanova appealed the July 29, 2024 contempt/injunction order, the February 3, 2025 eviction order, the July 3, 2025 enforcement order, and the July 25, 2025 orders. Maslii filed no appellee brief; the court decided the case on Ivanova's pro se brief alone.
Holdings
The vacatur of the July 21, 2025 emergency order of protection is affirmed ; because Ivanova failed to provide a transcript or record of the July 25, 2025 proceeding, the court presumed the order conformed to law and had a sufficient factual basis ( Foutch v. O'Bryant ), and the record rebutted her claims of lack of notice and hearing.
The court lacks jurisdiction over the July 29, 2024 contempt/injunction order: although an indirect civil contempt order barring participation in the sale is injunctive under Rule 307(a)(1), the appeal was filed more than a year later, beyond the 30-day period.
The court lacks jurisdiction over the February 3, 2025 eviction and July 3, 2025 enforcement orders; a motion to reconsider does not toll the 30-day interlocutory appeal period.
The July 25, 2025 reiteration of the eviction order had no independent injunctive effect; the permission for Maslii to occupy the home was permissive, not prescriptive; and the contingent threat of custody imposed no penalty, so Rule 304(b)(5) did not apply.
Legal Principles
Ill. S. Ct. R. 307(a)(1), 307(a), 307(b), (d); Ill. S. Ct. R. 304(b)(5); Ill. S. Ct. R. 303; Ill. S. Ct. R. 375(a). Substance over form governs what is an appealable injunction ( In re M.S. ; In re A Minor ). Indirect civil contempt orders restraining conduct are appealable injunctions ( Bloomington Urological Associates, SC v. Scaglia ). Motions to reconsider do not toll the appeal period, including for Rule 307 appeals ( Dus v. Provena St. Mary's Hospital ; Tyler v. Highline Auto Sales, Inc. ). Orders of protection are injunctive in nature ( Fricke v. Jones ). Incomplete records are construed against the appellant ( Foutch v. O'Bryant ). Pro se litigants are held to attorney standards ( Williams ; Holzrichter v. Yorath ) and may be sanctioned in egregious circumstances ( Parkway Bank and Trust Co. v. Korzen ). On AI, the court follows Scott v. Illinois Human Rights Commission and In re Baby Boy : the only acceptable standard is zero false citations.
Practical Implications
Calendar interlocutory deadlines strictly: a contempt order enjoining a party from participating in a court-ordered sale is immediately appealable under Rule 307(a)(1), and waiting for a "final" judgment forfeits review.
Do not rely on a motion to reconsider to extend the 30-day window for interlocutory appeals.
Always secure a transcript, bystander's report, or agreed statement of facts; absent one, the reviewing court presumes the order was lawful and factually supported.
An expired order of protection confers no continuing exclusive possession; practitioners should seek timely extension in the issuing court.
Verify every citation personally. The court expressly warned that future filings with invented or inaccurate citations will draw a rule to show cause and Rule 375(a) sanctions, even against pro se litigants.
Distinguishing point: the court did not reach the merits of whether a spouse may be "evicted" from the marital home or whether the judicial deed and section 501 relief were proper, so those arguments remain open in a properly perfected appeal.
Limitations/Caveats
This is a Rule 23 order with no precedential value except under Rule 23(e)(1). The jurisdictional rulings and the affirmance of the vacatur are binding on the parties; the extensive discussion of generative AI misuse and the warning of future sanctions is largely admonitory dicta, as no sanctions were imposed. The merits of the contempt, eviction, and judicial-deed rulings were never reached.
Overview
In this pro se appeal from a Cook County dissolution case, the appellate court affirmed the circuit court's July 25, 2025 order vacating an emergency order of protection obtained by the wife, and dismissed the remainder of the appeal for lack of jurisdiction because the earlier contempt, eviction, and eviction-enforcement orders were not appealed within 30 days. The court also issued an extended warning about generative AI "hallucinated" citations in a pro se brief, declining to sanction this time but promising a rule to show cause for any future offending filings.
Key Facts
Maslii petitioned for dissolution in April 2022; the parties owned a marital home in Rolling Meadows.
Ivanova obtained a plenary criminal order of protection on January 30, 2023 giving her exclusive possession of the marital home, extended through June 30, 2025.
The court ordered the home sold in September 2023 after Maslii showed he could no longer carry the mortgage, taxes, and expenses; a listing agent was appointed.
Maslii filed repeated motions alleging Ivanova obstructed the sale (blocking showings, refusing to sign documents, altering terms); the listing agent was separately reprimanded for failing to disclose at least one offer.
On July 29, 2024, the court found Ivanova in contempt, barred her from involvement in the sale, and entered a judicial deed vesting the home in Maslii for sale purposes under section 501 injunctive relief.
The court entered an eviction order February 3, 2025 and an enforcement order July 3, 2025 directing the Sheriff to remove her.
On July 21, 2025 (after the criminal order of protection had expired and an extension was denied), Ivanova obtained an emergency civil order of protection alleging Maslii entered the home; the court vacated it July 25, 2025, finding she had lied about her residence and concealed the eviction orders.
Notice of appeal filed August 25, 2025.
Procedural History
Appeal from the Circuit Court of Cook County, No. 2022 D 003121 (Hon. Patricia M. Fallon). Ivanova appealed the July 29, 2024 contempt/injunction order, the February 3, 2025 eviction order, the July 3, 2025 enforcement order, and the July 25, 2025 orders. Maslii filed no appellee brief; the court decided the case on Ivanova's pro se brief alone.
Holdings
The vacatur of the July 21, 2025 emergency order of protection is affirmed ; because Ivanova failed to provide a transcript or record of the July 25, 2025 proceeding, the court presumed the order conformed to law and had a sufficient factual basis ( Foutch v. O'Bryant ), and the record rebutted her claims of lack of notice and hearing.
The court lacks jurisdiction over the July 29, 2024 contempt/injunction order: although an indirect civil contempt order barring participation in the sale is injunctive under Rule 307(a)(1), the appeal was filed more than a year later, beyond the 30-day period.
The court lacks jurisdiction over the February 3, 2025 eviction and July 3, 2025 enforcement orders; a motion to reconsider does not toll the 30-day interlocutory appeal period.
The July 25, 2025 reiteration of the eviction order had no independent injunctive effect; the permission for Maslii to occupy the home was permissive, not prescriptive; and the contingent threat of custody imposed no penalty, so Rule 304(b)(5) did not apply.
Legal Principles
Ill. S. Ct. R. 307(a)(1), 307(a), 307(b), (d); Ill. S. Ct. R. 304(b)(5); Ill. S. Ct. R. 303; Ill. S. Ct. R. 375(a). Substance over form governs what is an appealable injunction ( In re M.S. ; In re A Minor ). Indirect civil contempt orders restraining conduct are appealable injunctions ( Bloomington Urological Associates, SC v. Scaglia ). Motions to reconsider do not toll the appeal period, including for Rule 307 appeals ( Dus v. Provena St. Mary's Hospital ; Tyler v. Highline Auto Sales, Inc. ). Orders of protection are injunctive in nature ( Fricke v. Jones ). Incomplete records are construed against the appellant ( Foutch v. O'Bryant ). Pro se litigants are held to attorney standards ( Williams ; Holzrichter v. Yorath ) and may be sanctioned in egregious circumstances ( Parkway Bank and Trust Co. v. Korzen ). On AI, the court follows Scott v. Illinois Human Rights Commission and In re Baby Boy : the only acceptable standard is zero false citations.
Practical Implications
Calendar interlocutory deadlines strictly: a contempt order enjoining a party from participating in a court-ordered sale is immediately appealable under Rule 307(a)(1), and waiting for a "final" judgment forfeits review.
Do not rely on a motion to reconsider to extend the 30-day window for interlocutory appeals.
Always secure a transcript, bystander's report, or agreed statement of facts; absent one, the reviewing court presumes the order was lawful and factually supported.
An expired order of protection confers no continuing exclusive possession; practitioners should seek timely extension in the issuing court.
Verify every citation personally. The court expressly warned that future filings with invented or inaccurate citations will draw a rule to show cause and Rule 375(a) sanctions, even against pro se litigants.
Distinguishing point: the court did not reach the merits of whether a spouse may be "evicted" from the marital home or whether the judicial deed and section 501 relief were proper, so those arguments remain open in a properly perfected appeal.
Limitations/Caveats
This is a Rule 23 order with no precedential value except under Rule 23(e)(1). The jurisdictional rulings and the affirmance of the vacatur are binding on the parties; the extensive discussion of generative AI misuse and the warning of future sanctions is largely admonitory dicta, as no sanctions were imposed. The merits of the contempt, eviction, and judicial-deed rulings were never reached.
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