Gordon v. Nickerson
Nonprecedential Rule 23(b) written order.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it was entered on or after January 1, 2021, it may be cited for persuasive purposes under Rule 23(e)(1), but it is not binding precedent.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 expedited pro se appeal, the Fifth District affirmed a St. Clair County judgment granting the father a multi-family child support adjustment, an alternating-year tax exemption, and equal (week-on/week-off) parenting time. The court also upheld denial of the mother's indirect civil contempt petitions and the refusal to consider unauthenticated police body camera footage.
Key Facts
Father petitioned for allocation of parental responsibilities of the minor (born April 2024), seeking joint decision-making and equal parenting time; IDHFS intervened under Title IV-D and filed a support complaint.
A February 21, 2025, temporary order gave Mother all parenting time after Father walked out of the courtroom before the ruling; Father later apologized in writing for his conduct.
Temporary support was $835/month plus $66.34 insurance, calculated with a multi-family adjustment for Mother's two other children but not Father's two other children (no evidence had been presented).
The August 27, 2025, order analyzed all statutory best-interest factors, found no evidence of physical violence toward the minor, found both parties engaged in "petty behavior," and found Mother had used the temporary order to block Father's parenting time for six months.
Support was reduced to $435.31/month (multi-family adjustment without court order, deducting $1,020.75 from net income of $3,967), plus $61.28 insurance, and the tax exemption was alternated.
The May 8, 2026, amended plan gave equal alternating-week parenting time to reduce exchange conflicts; Mother's contempt petitions (Indiana relocation, transportation by Father's girlfriend, withheld belongings, hair styling) were denied.
Mother failed to include transcripts or a Rule 323(c)/(d) substitute for most hearings and annotated a partial transcript herself.
Procedural History
Appeal from the circuit court of St. Clair County (No. 24-FA-203, Judge Alana I. Mejias). Mother appealed the May 8, 2026, final/amended parenting time order and the August 27, 2025, parenting time order; the appeal was expedited under Rule 311(a) .
Holdings
The August 27, 2025, order was reviewable because it was a procedural step in the progression leading to the May 8, 2026, final judgment ( Knapp v. Bulun ).
The multi-family adjustment was not an abuse of discretion; section 505(a)(3)(F)(I)(ii) permits deducting 75% of guideline support for other children, and no proof of actual payments was required. Mother's economic hardship claim did not show arbitrariness.
The tax exemption argument was forfeited for failure to cite authority under Rule 341(h)(7) .
Equal parenting time was neither an abuse of discretion nor against the manifest weight of the evidence, where the court addressed all section 602.7(b) factors with detailed findings.
Denial of the contempt petitions was proper; Mother did not show any court order was violated, much less willfully or contumaciously.
Exclusion of Evansville police body camera footage was proper absent authentication by a witness with personal knowledge ( People ex rel. Sherman v. Cryns ).
Legal Principles
750 ILCS 5/505(a)(3)(F) (West 2024) (multi-family adjustment, with and without court order); 750 ILCS 5/602.7(a), (b) (West 2024) (17 best-interest factors); 42 U.S.C. § 651 et seq.; 305 ILCS 5/10-1 et seq.; Ill. S. Ct. Rules 311(a), 323, 341(h)(7). Foutch v. O'Bryant , 99 Ill. 2d 389 (appellant's record burden; presumption of conformity with law). Roper v. Johns , 345 Ill. App. 3d 1127; In re Parentage of I.I. , 2016 IL App (1st) 160071; In re Marriage of Whitehead , 2018 IL App (5th) 170380; Jameson v. Williams , 2020 IL App (3d) 200048; In re Marriage of McCormick , 2013 IL App (2d) 120100; Melamed v. Melamed , 2016 IL App (1st) 141453; Lill Coal Co. v. Bellario , 30 Ill. App. 3d 384.
Practical Implications
Put evidence of a client's other children in the record early—the court here corrected the initial one-sided adjustment once proof was presented.
The opinion confirms the "without court order" adjustment does not require proof of actual payments; 75% of guideline support may be deducted instead.
Using a temporary order to block the other parent's time can backfire; the court expressly criticized that conduct while treating a parent's courtroom outburst (followed by apology and improved behavior) as non-disqualifying.
Contempt requires a specific order prohibition—"obnoxious" but unprohibited conduct (out-of-state travel during parenting time, handing off to a non-designated adult after an authorized pickup) is not contumacious. Draft parenting plans with express restrictions if you want them enforceable.
Relocation provisions keyed to the residential parent's move do not restrict temporary travel during the other parent's time.
Authenticate body camera or video evidence through a witness with personal knowledge; a subpoenaed records custodian/officer is essential.
Incomplete records are fatal: without transcripts or a bystander's report, all doubts resolve against the appellant.
Limitations/Caveats
This is a Rule 23 order and is not precedent except under Rule 23(e)(1). Much of the analysis rests on the deferential standards of review and the incomplete record, so its persuasive force is fact-bound. The court's observations about parties' "petty behavior" and exchange logistics are explanatory, not holdings.
Overview
In this expedited pro se appeal, the Fifth District affirmed a St. Clair County judgment granting the father a multi-family child support adjustment, an alternating-year tax exemption, and equal (week-on/week-off) parenting time. The court also upheld denial of the mother's indirect civil contempt petitions and the refusal to consider unauthenticated police body camera footage.
Key Facts
Father petitioned for allocation of parental responsibilities of the minor (born April 2024), seeking joint decision-making and equal parenting time; IDHFS intervened under Title IV-D and filed a support complaint.
A February 21, 2025, temporary order gave Mother all parenting time after Father walked out of the courtroom before the ruling; Father later apologized in writing for his conduct.
Temporary support was $835/month plus $66.34 insurance, calculated with a multi-family adjustment for Mother's two other children but not Father's two other children (no evidence had been presented).
The August 27, 2025, order analyzed all statutory best-interest factors, found no evidence of physical violence toward the minor, found both parties engaged in "petty behavior," and found Mother had used the temporary order to block Father's parenting time for six months.
Support was reduced to $435.31/month (multi-family adjustment without court order, deducting $1,020.75 from net income of $3,967), plus $61.28 insurance, and the tax exemption was alternated.
The May 8, 2026, amended plan gave equal alternating-week parenting time to reduce exchange conflicts; Mother's contempt petitions (Indiana relocation, transportation by Father's girlfriend, withheld belongings, hair styling) were denied.
Mother failed to include transcripts or a Rule 323(c)/(d) substitute for most hearings and annotated a partial transcript herself.
Procedural History
Appeal from the circuit court of St. Clair County (No. 24-FA-203, Judge Alana I. Mejias). Mother appealed the May 8, 2026, final/amended parenting time order and the August 27, 2025, parenting time order; the appeal was expedited under Rule 311(a) .
Holdings
The August 27, 2025, order was reviewable because it was a procedural step in the progression leading to the May 8, 2026, final judgment ( Knapp v. Bulun ).
The multi-family adjustment was not an abuse of discretion; section 505(a)(3)(F)(I)(ii) permits deducting 75% of guideline support for other children, and no proof of actual payments was required. Mother's economic hardship claim did not show arbitrariness.
The tax exemption argument was forfeited for failure to cite authority under Rule 341(h)(7) .
Equal parenting time was neither an abuse of discretion nor against the manifest weight of the evidence, where the court addressed all section 602.7(b) factors with detailed findings.
Denial of the contempt petitions was proper; Mother did not show any court order was violated, much less willfully or contumaciously.
Exclusion of Evansville police body camera footage was proper absent authentication by a witness with personal knowledge ( People ex rel. Sherman v. Cryns ).
Legal Principles
750 ILCS 5/505(a)(3)(F) (West 2024) (multi-family adjustment, with and without court order); 750 ILCS 5/602.7(a), (b) (West 2024) (17 best-interest factors); 42 U.S.C. § 651 et seq.; 305 ILCS 5/10-1 et seq.; Ill. S. Ct. Rules 311(a), 323, 341(h)(7). Foutch v. O'Bryant , 99 Ill. 2d 389 (appellant's record burden; presumption of conformity with law). Roper v. Johns , 345 Ill. App. 3d 1127; In re Parentage of I.I. , 2016 IL App (1st) 160071; In re Marriage of Whitehead , 2018 IL App (5th) 170380; Jameson v. Williams , 2020 IL App (3d) 200048; In re Marriage of McCormick , 2013 IL App (2d) 120100; Melamed v. Melamed , 2016 IL App (1st) 141453; Lill Coal Co. v. Bellario , 30 Ill. App. 3d 384.
Practical Implications
Put evidence of a client's other children in the record early—the court here corrected the initial one-sided adjustment once proof was presented.
The opinion confirms the "without court order" adjustment does not require proof of actual payments; 75% of guideline support may be deducted instead.
Using a temporary order to block the other parent's time can backfire; the court expressly criticized that conduct while treating a parent's courtroom outburst (followed by apology and improved behavior) as non-disqualifying.
Contempt requires a specific order prohibition—"obnoxious" but unprohibited conduct (out-of-state travel during parenting time, handing off to a non-designated adult after an authorized pickup) is not contumacious. Draft parenting plans with express restrictions if you want them enforceable.
Relocation provisions keyed to the residential parent's move do not restrict temporary travel during the other parent's time.
Authenticate body camera or video evidence through a witness with personal knowledge; a subpoenaed records custodian/officer is essential.
Incomplete records are fatal: without transcripts or a bystander's report, all doubts resolve against the appellant.
Limitations/Caveats
This is a Rule 23 order and is not precedent except under Rule 23(e)(1). Much of the analysis rests on the deferential standards of review and the incomplete record, so its persuasive force is fact-bound. The court's observations about parties' "petty behavior" and exchange logistics are explanatory, not holdings.
Disclaimer: This case summary is for informational purposes only and does not constitute legal advice.
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