In re Marriage of Hackney, No. 1-21-0380 (Ill. App. Ct. 1st Dist. Nov. 23, 2021) (2021 IL App (1st) 210380-U)

1) Case citation and parties
- In re the Marriage of Christina Hackney (petitioner-appellee) and Travis Hackney (respondent-appellant). Appeal from Cook County; Rule 23 order (non‑precedential).

2) Key legal issues
- Whether the trial court erred in its March 24, 2021 allocation (parenting/custody) judgment: appellant argued (pro se) that the order was entered ex parte, that necessary documentation/transcripts were not provided for appeal, that he was improperly charged fees, and that the allocation was otherwise unsupported. More broadly: sufficiency of the record for appellate review and deference to trial court credibility findings in custody/allocation determinations.

3) Holding / outcome
- Affirmed. The appellate court held appellant failed to raise substantive legal errors or supply a record basis for reversal; the allocation judgment must be presumed proper where it is supported by testimony and evidence considered by the trial court.

4) Significant legal reasoning
- The court emphasized an appellate presumption that trial-court findings, especially credibility determinations based on witness demeanor, are correct when supported by the record. Here the allocation order expressly stated the trial court observed witnesses (parties, guardian ad litem, nanny, others) and found Christina and other witnesses credible and Travis not credible.
- The record on appeal was incomplete (transcripts of key testimony were missing); appellant, proceeding pro se, did not provide the transcript(s) needed to show error. The appellate court stressed the appellant’s burden to present a sufficiently complete record to permit review — absent that, contested factual findings that depend on witness credibility cannot be reversed.
- The trial court’s factual findings (danger to child’s welfare, failure to comply with prior orders concerning firearms and paraphernalia, incidents reported at daycare, bringing a bullet into court) provided a factual basis for awarding sole parental responsibility and supervised parenting time. The court rejected procedural/contention arguments (ex parte, fees) because appellant did not show legal error in the record.

5) Practice implications (concise)
- Preserve and develop the record: custody appellants (particularly pro se) must ensure transcripts and supporting documents are included to challenge credibility-based factual rulings.
- Credibility/demeanor findings by the trial judge carry heavy deference on appeal in allocation disputes.
- Compliance with court orders (weapons, substance‑use restrictions) is critical; documented noncompliance will underpin restrictions on parenting time.
- Challenges to administrative procedures, fees, or alleged ex parte actions require record evidence and specific legal argumentation to succeed on appeal.