In re Marriage of Goldsby, 2021 IL App (4th) 200001-U

Case citation and parties
1. In re Marriage of Goldsby, 2021 IL App (4th) 200001‑U (Ill. App. Ct., 4th Dist. Mar. 29, 2021) (Rule 23 order; non‑precedential). Petitioner‑Appellee: Kathryn Ann Goldsby. Respondent‑Appellant: Bruce A. Goldsby.

Key legal issues
2. (a) Whether the trial court erred in modifying a decades‑old child‑support obligation for a disabled adult child. (b) Whether the court erred in finding respondent in indirect civil contempt for willfully failing to pay the ordered support. (c) Whether the appellant’s procedural default or timeliness of his notice of appeal limited appellate review.

Holding / outcome
3. The appellate court affirmed the trial court’s December 2, 2019 contempt judgment. It held it lacked jurisdiction to review the August 12, 2019 child‑support modification because the appellant’s notice of appeal was untimely as to that order. The contempt order (timely appealed) was left intact.

Significant legal reasoning
4. - Jurisdiction and timeliness: The court applied Illinois Supreme Court Rules 301 and 303 and controlling precedent (e.g., Pappas, Steinbrecher, Patrick) to conclude a timely notice of appeal confers appellate jurisdiction only as to the judgment(s) specified. Bruce’s notice, filed Jan. 2, 2020, was untimely to challenge the August 12, 2019 modification (30‑day rule), so that portion of the appeal was dismissed for lack of jurisdiction.
- Contempt judgment: The December 2, 2019 contempt order was timely appealed. The appellant, however, advanced no specific challenge to the contempt determination on the merits and largely attacked the underlying modification (which was unappealable due to timeliness). The trial court’s factual finding that Bruce willfully failed to comply with the support order and the imposition of purge payments ($169/mo plus $33.80 toward arrearage) was affirmed.
- Collateral‑benefit argument rejected at contempt stage: The trial court declined to accept the contention that payments would reduce the disabled child’s SSI as a defense to contempt, observing that the contempt hearing’s purpose was to enforce compliance, not to re‑litigate benefit‑impact issues.

Practice implications
5. - Appeal discipline: Timely and precise notices of appeal are jurisdictional—appeal or seek interlocutory relief within the 30‑day window for any final modification order. Specify each order appealed.
- Preservation at trial: If the obligor’s financial inability or the interaction with public benefits (e.g., SSI) is central, present evidence and legal argument at the modification hearing and obtain a written ruling; preserve those claims for appeal.
- Contempt defense: If alleged inability to pay is the defense to contempt, develop admissible evidence of income, assets, and inability to comply at the contempt hearing; failure to do so greatly reduces chances of reversal.
- Practice note: Rule 23 opinions are non‑precedential; nonetheless, the decision reiterates that contempt remains a coercive, purgeable remedy to enforce court‑ordered support.