In re Marriage of Johnson, 2019 IL App (4th) 180831-U

- Case citation and parties
In re Marriage of Johnson, 2019 IL App (4th) 180831-U (Ill. App. Ct. July 18, 2019) (Rule 23 non‑precedential). Petitioner-Appellee: Antoine L. Johnson. Respondent-Appellant: Anna B. Johnson (n/k/a Anna B. Agustin).

- Key legal issues
1. Whether the trial court erred in denying respondent’s emergency and plenary petitions for orders of protection.
2. Whether the court erred in denying a continuance of petitioner’s emergency indirect‑civil‑contempt proceeding.
3. Whether the court properly found respondent interfered with (abused) petitioner’s allocated parenting time.
4. Legality of imposing a bond under 750 ILCS 5/607.5(c)(4) rather than finding contempt.
5. Whether the trial court abused its discretion in transferring further proceedings to Cook County.

- Holding/outcome
The Fourth District affirmed. The trial court’s denials of Anna’s petitions for protection were upheld; the court’s finding that Anna interfered with Antoine’s parenting time was affirmed; the imposition of a compliance bond under 750 ILCS 5/607.5 was sustained; and the transfer to Cook County was affirmed. The trial court clarified it did not find respondent in contempt. A Rule 304(a) finding was entered.

- Significant legal reasoning (concise)
The appellate court applied deferential review to the trial court’s factual and credibility determinations. The trial court heard competing testimony and video evidence of the September 2018 incident; the recordings were inconclusive and the judge declined to credit respondent’s version sufficient to grant an order of protection or to modify parenting time. The court found respondent had obstructed petitioner’s allotted parenting exchanges and thus warranted sanctions to secure compliance. The bond was imposed under the statutory authority of section 607.5 as a non‑contempt compliance mechanism; the appellate court accepted the trial court’s explanation that contempt was not imposed. The transfer was supported by the parenting allocation plan (filed May 18, 2018) that showed parties’ residence in Cook County and directed school and exchange terms, supporting venue/administrative transfer.

- Practice implications for family law attorneys
- Trial courts get wide latitude on credibility — preserve error with specific objections and a clear record when challenging credibility or evidentiary rulings.
- Parenting allocation plans (and their stated venue/residency facts) can control venue and enforcement — ensure consistency and timely filings in the appropriate county.
- Where parenting‑time interference occurs, courts may impose bonds under §607.5 as a compliance tool rather than immediate contempt — consider this remedy when seeking enforcement.
- Video evidence can be persuasive but may be inconclusive; corroborating testimony and clear timestamps/chain of custody help.
- When seeking protective relief amid parallel criminal or out‑of‑county orders, coordinate venue and document why emergency relief is required in the forum chosen.