In re Marriage of Bambic, 2019 IL App (1st) 182311-U

- Case citation and parties
In re Marriage of Bambic, 2019 IL App (1st) 182311-U (Nov. 1, 2019) (Rule 23 order). Petitioner-Appellant: David F. Bambic. Respondent-Appellee: Catherine M. Wood.

- Key legal issues
1) Whether the trial court erred in entering an order finding Bambic owed $41,397.66 in child‑support arrearages.
2) Whether Bambic’s due‑process and fraud claims regarding the Child Support Division’s calculations were reviewable given the appellate record.
3) Whether Bambic’s failure to comply with Illinois Supreme Court Rule 341(h) (appellate brief/record requirements) and to provide a complete record forfeited review.

- Holding/outcome
The First District affirmed the trial court’s May 31, 2018 order and the denial of Bambic’s motion to reconsider. The court declined to strike the appeal despite Rule 341 noncompliance, but affirmed on the merits because the record was insufficient to overcome the presumption that the trial court’s ruling conformed to law.

- Significant legal reasoning
The panel stressed that appellants bear the burden of supplying a sufficiently complete record and presenting reasoned argument with record citations (Ill. S. Ct. R. 341(h)). Pro se status does not excuse compliance. Where the record is incomplete, Foutch v. O’Bryant instructs appellate courts to presume the trial court acted correctly and to resolve ambiguities against the appellant. Bambic failed to include transcripts, the March 30, 2018 supporting order, bystander’s reports, or the specific motion the May 31 order addressed, and his brief contained argumentative and irrelevant material rather than properly cited facts and authorities. Although the court noted striking the brief would have been an option, it addressed the appeal and found the record inadequate to support his due‑process/fraud claims or to show reversible error.

- Practice implications (concise)
- Strictly follow Ill. S. Ct. R. 341(h): present clear, non‑argumentative facts with pinpoint record citations and reasoned legal argument.
- Pro se litigants receive no procedural leniency on appellate technicalities.
- Ensure transcripts, bystander’s reports, or agreed statements and any underlying administrative or trial orders challenged are included in the record; if omitted, appellate courts will presume the trial court’s correctness (Foutch) and dismiss or affirm.
- If clerk’s record is incomplete, promptly move to supplement or correct the record and document efforts to comply with any appellate court directions.