In re Parentage of Cali F.

Overview

Pro se appellant Christina B., the maternal grandmother and legal guardian of minor Cali F., appealed the circuit court's denial of her petition for rule to show cause against the child's father, Christopher F. The Fifth District affirmed, finding that Christina failed to provide an adequate record on appeal—specifically, no report of proceedings or acceptable substitute—and therefore the court presumed the circuit court ruled correctly.

Key Facts

Christopher F. filed a parentage petition in April 2024 regarding Cali F., age 6, who had been living with maternal grandmother Christina B.

Christina was appointed plenary guardian of Cali with sole decision-making authority and primary parenting time; Christopher received agreed visitation.

A February 3, 2026, agreed order governed visitation terms.

Christina filed a petition for rule to show cause alleging Christopher violated the February 2026 order on March 13–14, 2026, by refusing to provide the name and location of a hair stylist who braided Cali's hair.

The circuit court denied the petition after a hearing where both parties testified under oath.

Christina appealed pro se; Christopher did not file an appellee brief.

Procedural History

Circuit Court of Randolph County, Case No. 24-FA-20, Judge Lucas H. Liefer presiding. Related guardianship case No. 23-GR-17 ran concurrently. The petition for rule to show cause was denied on May 13, 2026. Christina filed a timely notice of appeal on May 27, 2026, to the Fifth District Appellate Court.

Holdings

Primary holding: Affirmed the denial of the petition for rule to show cause. The standard of review for contempt findings is manifest weight of the evidence , but the court could not reach the merits because the appellant failed to provide an adequate record on appeal (no transcript, bystander's report, or agreed statement of facts).

Secondary holding: The absence of an appellee brief does not warrant automatic reversal, citing People v. Williams , 339 Ill. App. 3d 956, 958 (2003) .

Legal Principles

Ill. S. Ct. R. 323(c), (d) — requires a report of proceedings or acceptable substitute (bystander's report or agreed statement of facts) for appellate review.

People v. Hunt , 234 Ill. 2d 49, 58 (2009) — the appellant bears the burden of presenting an adequate record; doubts from an inadequate record are construed against the appellant.

Smolinski v. Vojta , 363 Ill. App. 3d 752, 757 (2006) — where the record is incomplete, the court will not speculate about errors and will indulge every reasonable presumption in favor of the circuit court's judgment.

Practical Implications

Always secure the transcript: Pro se or represented, failure to include a report of proceedings or Rule 323 substitute is virtually fatal to any appeal challenging an evidentiary ruling.

Contempt petitions over minor compliance disputes: This case illustrates the difficulty of obtaining contempt findings for arguably marginal violations (refusing to disclose a hair stylist's name). Practitioners should carefully evaluate whether alleged conduct constitutes a clear, unambiguous violation of a court order before filing.

Draft precise agreed orders: The underlying dispute suggests the February 2026 order may not have explicitly addressed information-sharing about third-party service providers. Practitioners should draft orders with specificity regarding communication obligations.

No automatic reversal for missing appellee brief: Do not rely on an opposing party's failure to respond on appeal as a path to reversal.

Limitations/Caveats

This is a Rule 23 order with limited precedential value under Ill. S. Ct. R. 23(e)(1). The court did not reach the merits of whether Christopher's conduct constituted contempt; the entire disposition rests on the inadequate record. The case offers no substantive guidance on the scope of guardian decision-making authority or contempt standards in parentage/guardianship hybrid cases—those issues are entirely unaddressed dicta at best.