In re Marriage of Pittman, 2019 IL App (1st) 161316-U

1. Case citation and parties
- In re Marriage of Pittman, No. 1-16-1316, 2019 IL App (1st) 161316-U (Ill. App. Ct., 1st Dist., June 28, 2019) (Rule 23 non‑precedential order).
- Petitioner-Appellant: Debbie Pittman (pro se). Respondent-Appellee: Ronnie Pittman.

2. Key legal issues
- Whether the appellate court had jurisdiction given alleged untimely notices of appeal raising ~20 post‑judgment issues.
- Whether the trial court abused its discretion in finding petitioner in indirect civil contempt and imposing a purgable monetary sanction ($15,000) and attorney‑fee awards.
- Ancillary procedural issues asserted by petitioner: ADA accommodation, substitution of judge, exclusion of witnesses for untimely lists, discovery sanctions, characterization and division of marital assets (TSP, structured settlement, real property), and award/modification of financial relief.

3. Holding/outcome
- The appellate court concluded it lacked jurisdiction over almost all of petitioner’s claims because her notices of appeal were untimely, except for issues relating to indirect civil contempt (the only claims timely before the court). As to the contempt claims that were before the court, the appellate court affirmed: the trial court did not abuse its discretion in finding petitioner in indirect civil contempt and imposing the purgable sanction. The other myriad appellate challenges were dismissed for lack of jurisdiction. (Order filed under Rule 23 — non‑precedential.)

4. Significant legal reasoning
- Timeliness/jurisdiction: The court dismissed most issues because petitioner failed to meet required time limits for filing notices of appeal/post‑judgment motions; where appellate jurisdiction is lacking, the court will not reach the merits.
- Contempt standard: The court applied the abuse‑of‑discretion standard to the trial court’s contempt finding. It treated the sanction as civil (purgable) because the order contained a clear condition for compliance (i.e., purge payment), and the record supported the trial court’s factual findings that petitioner had removed/concealed marital assets and violated court orders (justifying TROs, sanctions, and fee shifting). Procedural protections for indirect contempt (opportunity to be heard) were considered and found adequate on the record.

5. Practice implications for family-law attorneys
- Preserve appellate rights: timely post‑judgment motions and notices of appeal are critical—failure to comply with appeal deadlines will foreclose review.
- Document discovery and service rigorously: discovery failures and untimely witness lists risk exclusion and sanctions; maintain clear proof of mailing/service dates.
- Asset protection: courts will use TROs, reallocation of marital assets, and fee awards to address suspected concealment; counsel should move promptly to freeze or trace assets when concealment is suspected.
- Contempt litigation: indirect contempt will be treated as civil when a purge exists; build a clear record (orders, violations, notice) and ensure due‑process opportunities are provided.
- ADA and pro se claims: raise accommodation requests and supporting proof at trial level and preserve contemporaneous objections in the record.
- Note: this is a Rule 23 non‑precedential decision — persuasive but not binding authority.