In re Marriage of Isom, 2025 IL App (3d) 240491-U

1. Case citation and parties
- In re Marriage of Isom, 2025 IL App (3d) 240491‑U (Ill. App. Ct., 3d Dist. June 16, 2025) (Rule 23 order — nonprecedential).
- Petitioner‑Appellee: Angela Isom. Respondent‑Appellant: Gbolahan Kareem.

2. Key legal issues
- Whether the trial court abused its discretion in denying a post‑dissolution motion to reduce child support based on a claimed substantial change in circumstances (loss/expiration of U.S. work authorization).
- Whether the appellant preserved an adequate record and legal argument for appellate review.

3. Holding/outcome
- Affirmed. The appellate court concluded the record and appellant’s brief were inadequate to show abuse of discretion in denying the requested reduction. The court also emphasized the matter is not precedential under Supreme Court Rule 23.

4. Significant legal reasoning
- Standard of review: because the trial court found the change in circumstances voluntary, the denial of modification was reviewed for abuse of discretion.
- Record deficiencies: appellant failed to supply a report of proceedings, bystander’s report, or agreed statement from the July 12, 2024 hearing, despite the trial court’s order explicitly relying on “reasons stated of record.” Under Foutch, absent a sufficient record, appellate court must presume the trial court acted properly.
- Substantive proof lacking: appellant did not provide income figures (past/current/potential) or documentary proof (e.g., CIS correspondence) in the appellate record to demonstrate involuntariness or reduced ability to pay.
- Briefing failures: appellant’s brief contained incorrect/unsupported citations and violated Rule 341(h)(7) by failing to cite authorities and record pages. The court noted self‑represented litigants remain bound by the same procedural rules.
- Prior context: trial court had previously imputed income for willful underemployment and the parties’ marital settlement agreement (MSA), incorporated into the judgment, set child support at $909/month — relevant background weighed by the trial court.

5. Practice implications (concise)
- Preserve the record: obtain and include complete transcripts, bystander reports, or an agreed statement of proceedings for any hearing you will appeal.
- Document financial change: attach pay stubs, tax returns, job search evidence, and all governmental notices (e.g., CIS letters) to both the trial and appellate records.
- Address voluntariness directly at hearing: make an evidentiary proffer about why loss of work authorization is involuntary and how it affects earning capacity to avoid imputation.
- Beware settlement clauses: MSAs incorporated into judgments carry force; plan arguments about modification (and any express modification waiver) accordingly.
- Appellate briefing: comply strictly with Rule 341 requirements and verify citations — insufficiency may forfeit appellate review.