In re Marriage of Liu, 2025 IL App (5th) 241199-U

1. Case citation and parties
- In re Marriage of Liu, No. 5-24-1199, 2025 IL App (5th) 241199-U (filed Mar. 19, 2025) (Rule 23 order; nonprecedential).
- Petitioner-Appellee: Meng Liu (mother). Respondent-Appellant: Jonathan Cox (father).

2. Key legal issues
- Whether the appeal from the trial court’s parenting-time/allocation orders (including summer schedule and passport directive) could proceed despite the appellant’s procedural defaults on appeal.
- Whether noncompliance with Illinois Supreme Court Rules 311 (accelerated schedule), 341 (appellant’s brief), and 342 (appendix) justified dismissal.

3. Holding/outcome
- Appeal dismissed for want of prosecution and for failure to comply with Rules 341 and 342. Appellant’s late, four‑page brief and untimely appendix were stricken; dismissal was entered in the trial court’s favor.

4. Significant legal reasoning
- The Fifth District emphasized that Supreme Court rules have the force of law and compliance is mandatory. The court reviewed the appellant’s brief against Rule 341(h) requirements and found nearly all required subparts missing: table of contents, introductory paragraph, statement of issues, statement of jurisdiction, statement of facts, and an argument with citations to authorities and record pages.
- Appellant also failed to meet accelerated scheduling obligations under Rule 311 (brief due Feb. 27, 2025), ignored a show-cause order, and filed a late brief and appendix without leave of court.
- The panel observed the brief conceded mootness of the passport issue and presented only conclusory “suggestions” re: unfairness of unequal summer parenting time without statutory or case-law support. Citing precedents that appellate courts are not repositories for undeveloped argument, the court exercised its discretion to dismiss the appeal rather than reach the merits.

5. Practice implications
- Strict compliance with Rules 311, 341, and 342 is essential—especially in custody matters on an accelerated track. Missing filing deadlines, failing to respond to show‑cause orders, or submitting a skeletal brief lacking required sections and record citations risks dismissal.
- If delays are unavoidable, promptly move for leave to file late, for an extension, or for a stay, and explain why; timely opposition to a dismissal motion or a substantive response to an order to show cause is critical.
- For custody appeals, preserve detailed record citations and develop cogent legal arguments supported by authority and record references (Rule 341(h)(7)). Failure to do so may forfeit appellate review and leave the trial court’s orders intact.