In re Marriage of Thompson, 2025 IL App (1st) 250562-U

Facts

Rashida Thompson appealed post-dissolution orders restricting her telephone contact with children during Christopher Thompson's parenting time and prohibiting wellness check calls. The First District appellate court reviewed the procedural adequacy of the appeal including timeliness and whether proper leave was sought for the interlocutory custody order.

Issue

Whether the appellate court had jurisdiction to review post-dissolution orders restricting parental contact and prohibiting wellness checks when proper appellate procedures were not followed.

Holding

The First District dismissed the appeal for lack of appellate jurisdiction. The court found that appellant failed to obtain proper appealable basis through either timely appeal from final judgment or leave to pursue interlocutory appeal under custody rules.

Key Reasoning

• Post-dissolution custody orders require specific appellate procedures including either timely final judgment appeal or leave for interlocutory appeal
• Procedural deficiencies in the appellate record, including absence of trial transcripts, impeded meaningful review
• Appellate jurisdiction requirements must be strictly met before courts can reach the merits of custody disputes
• Failure to follow correct appellate vehicle automatically results in dismissal regardless of underlying merits