In re Marriage of Glod, 2025 IL App (1st) 240403‑U

1) Case citation and parties
- In re Marriage of Glod, No. 1-24-0403 (Ill. App. Ct., 1st Dist., Apr. 11, 2025) (Rule 23 order).
- Petitioner‑Appellee: Jacek Glod. Respondent‑Appellant: Marta Glod.

2) Key legal issues
- Whether the appellate court has jurisdiction to review an interlocutory order denying a motion for substitution (disqualification) of a judge for cause under 735 ILCS 5/2‑1001(a)(3).
- Whether other nonfinal orders identified in the notice of appeal (May 4, 2022 and July 27, 2022) are separately appealable.

3) Holding / outcome
- The appellate court dismissed the appeal for lack of jurisdiction. The order denying Marta’s motion to substitute the judge for cause is interlocutory, not a final and appealable order, so the court may not review it on this appeal.

4) Significant legal reasoning
- The court reaffirmed its duty to examine jurisdiction sua sponte and applied Illinois Supreme Court Rule 301: only final circuit‑court judgments are appealable as of right.
- Citing precedent (including In re Marriage of Arjmand, 2024 IL 129155, and In re Inland Commercial Property Management, 2015 IL App (1st) 141051), the court held that denial of a substitution motion for cause is not a final order and therefore is not independently appealable. Such denials are interlocutory and reviewable only on appeal from a subsequent final judgment (or, in limited circumstances, by extraordinary relief).
- The court also noted the May 4 and July 27, 2022 orders identified in the notice of appeal likewise were not final because they did not terminate the litigation or dispose of rights on the merits.

5) Practice implications (concise)
- Motions to disqualify (substitute) judges under 735 ILCS 5/2‑1001(a)(3) typically cannot be appealed immediately; preserve the issue for appeal from the final judgment.
- Counsel should target notices of appeal to final, appealable orders per Rule 301 and avoid premature appeals that will be dismissed for lack of jurisdiction.
- If immediate review seems essential, consider extraordinary remedies (mandamus or supervisory writ), recognizing they are discretionary and rarely granted.
- Preserve a complete record of the substitution motion and related proceedings so the issue can be raised effectively on appeal from the final disposition.