In re Marriage of Lee, 2025 IL App (1st) 241564-U

- Case citation and parties
In re Marriage of Antoinette Jameica Lee, 2025 IL App (1st) 241564‑U (1st Dist. May 27, 2025). Petitioner-Appellee: Antoinette Jameica Lee. Respondent‑Appellant: Steven Jermaine Lee (appearing pro se / as “Bro. S. Lee Bey”).

- Key legal issues
1. Whether the trial court erred in granting dissolution after respondent failed to appear and was found in default.
2. Whether various jurisdictional challenges and post‑judgment filings (including filings by a “Moorish Science Temple” representative) deprived the court of jurisdiction or were improperly ignored.
3. Whether appellant’s appeal is reviewable when the record lacks a report of proceedings and the appellate brief fails to comply with Rule 341.

- Holding / outcome
Affirmed. The appellate court held the record was insufficient to review alleged trial‑court error and affirmed the dissolution judgment. Filings made on respondent’s behalf by a non‑lawyer were treated as nullities.

- Significant legal reasoning (concise)
- Appellant failed to provide a transcript or acceptable substitute (no report of proceedings, bystander’s report, or agreed statement) from the July 3, 2024 trial; under Foutch v. O’Bryant the appellate court must presume the trial court acted properly where the record is incomplete.
- Appellant’s brief violated Supreme Court Rule 341 (lack of cohesive legal argument, reliance on documents not in the record); those arguments are forfeited.
- Documents and motions submitted to the trial court by a non‑attorney (Prophet Noble Drew Ali / Moorish Science Temple) purporting to represent respondent were a nullity under Applebaum and related authority; a non‑attorney cannot represent another’s interests in Illinois courts.
- Certified‑mail receipts and documents attached to the appellate brief that were not part of the circuit‑court record cannot be considered on appeal.

- Practice implications for family lawyers
- Preserve a complete record for appeal: secure and order transcripts or prepare acceptable substitutes (bystander’s report or agreed statement) under Rule 323. Appeals lacking the record are usually doomed by Foutch.
- Pro se and opposing‑counsel pitfalls: non‑lawyers may not file or sign pleadings on behalf of others—such filings are nullities and will not toll deadlines or create appellate record.
- Ensure compliance with Rule 341 appellate brief requirements; noncompliant briefs risk forfeiture.
- For default/dissolution practice: document service, appearance/withdrawal of counsel, and hearings carefully; failure to appear risks default and inability to later challenge based on omitted record items.
- Be wary of “sovereign/religious nation” identity arguments and informal service proofs (certified‑mail receipts) — they rarely substitute for proper process or preserve appellate issues.