In re Marriage of Parrillo, 2024 IL App (1st) 240143-U

1. Case citation and parties
- In re Marriage of Parrillo, 2024 IL App (1st) 240143‑U (1st Dist. May 2, 2024) (Rule 23 order; non‑precedential).
- Petitioner‑Appellee: Jacqueline Parrillo. Respondent‑Appellant: Beau Parrillo.

2. Key legal issues
- Whether the appellate court had jurisdiction to hear an interlocutory appeal from a trial court’s nunc pro tunc amendment of a body‑attachment/commitment order.
- Whether the trial court abused its discretion by amending attachment language and modifying the civil‑contempt commitment so Beau could be released to home confinement with electronic monitoring upon payment of a reduced purge amount.

3. Holding/outcome
- The appellate court dismissed Beau’s appeal as to one amended attachment order for lack of appellate jurisdiction. As to the remaining challenge, the court affirmed the trial court’s orders allowing Beau’s release to home confinement upon payment of roughly half the originally‑stated purge amount and electronic monitoring; Beau failed to show error.

4. Significant legal reasoning
- Jurisdiction: The court emphasized limited circumstances when interlocutory orders are appealable (e.g., Illinois Supreme Court Rule 304(a) or other statutory bases). Because the trial court’s nunc pro tunc amendment of the November 13 attachment order did not carry an express Rule 304(a) finding and was interlocutory in nature, that portion of the appeal had to be dismissed for lack of jurisdiction.
- Merits: The contempt judgments were civil (coercive) proceedings tied to purge amounts. The trial court acted within its authority to clarify/correct the attachment order (changing “individual bond” to “cash bond” nunc pro tunc) and to set release conditions (home confinement with electronic monitoring) as an alternative means of coercion/relief. On the record (including Beau’s failure to appear personally at hearings and lack of proof that the court’s changed terms were inequitable), Beau did not demonstrate an abuse of discretion or legal error sufficient to disturb the trial court’s modifications.

5. Practice implications
- When seeking immediate appellate review of interlocutory family orders, obtain an express Rule 304(a) finding (or identify another statutory basis) to preserve appealability.
- Carefully draft and litigate attachment/commitment language (cash bond vs. individual/indemnity bond); seek prompt correction on the record if clerical or substantive errors exist.
- In civil‑contempt contexts, litigants should promptly document inability to pay (medical records, income proof) and move for alternatives (payment plans, home confinement, electronic monitoring). Courts retain broad equitable discretion to fashion purge mechanisms; absence of clear error on the record will make reversal unlikely.