In re Marriage of Thompson

Court: Illinois Appellate Court | Published: 8/27/2025
Marriage
Quick Summary: <h3>Case</h3> <strong>In re Marriage of Rashida Thompson v. Christopher Thompson</strong><br> 2025 IL App (1st) 250562‑U; Case No. 1‑25‑0562; Order filed Aug. 25, 2025. <h3>Court & Panel / Lower Cour...

Full Case Summary

Case

In re Marriage of Rashida Thompson v. Christopher Thompson
2025 IL App (1st) 250562‑U; Case No. 1‑25‑0562; Order filed Aug. 25, 2025.

Court & Panel / Lower Court

Appellate Court of Illinois, First District, Fourth Division — Presiding Justice Rochford; Justices Lyle and Ocasio concurred. Circuit Court of Cook County, No. 22 D 545; Hon. Jill Rose Quinn, presiding.

Procedural Posture

Appeal by pro se appellant Rashida Thompson from a Feb. 26, 2025 post‑dissolution order (challenging parental communications rules and sanctions). The appellate court dismissed the appeal for lack of jurisdiction.

Relevant Background & Chronology (concise)

- Parties: Rashida and Christopher Thompson, parents of three minors (San T., b. 2013; C.T., b. 2014; Sal T., b. 2016). Dissolution petition filed Jan. 24, 2022; dissolution judgment entered Dec. 12, 2023. - Early 2022: Emergency orders of protection (EOPs), a plenary POP proceeding threatened, appointment of GAL Erin M. Wilson (Feb. 22, 2022), a temporary “nesting” schedule (Mar. 17, 2022), and multiple emergency motions. - May 19, 2022: Court appointed Dr. Darlene Perry for a 604 evaluation (750 ILCS 5/604.1(b)). - Summer–Fall 2022: Orders modifying exchanges, prohibiting firearms around children, restricting presence of Rashida’s adult son Rahmad during her parenting time, and limiting daily contact to single contacts; orders required therapy and parenting coaching. - Jan.–July 2023: Competing motions, supervised visitation ordered for Rashida pending trial (May 12, 2023), GAL Wilson discharged after allocation trial; allocation judgment (July 25–27, 2023) ordered co‑parenting and removed restrictions on Rashida’s parenting time. - Late 2023–2024: Rashida filed emergency motions and appeals (dissolution affirmed by this court Sept. 26, 2024). Oct. 2024 EOP was entered then vacated (Oct. 15, 2024). - Feb. 19–21, 2025: Rashida filed new EOP petitions alleging multiple incidents in Feb. 2025, including an incident involving San. T.; one petition denied Feb. 20, 2025; another prompted police/medical involvement. Christopher filed emergency motions to modify and limit Rashida’s parenting and to enforce a prior order prohibiting police wellness calls during the other parent’s time. - Feb. 26, 2025 order: Court found an emergency, left the allocation judgment unchanged, limited each parent to one five‑minute phone call during the other’s parenting time, required cooperation with the GAL, and imposed a $1,000 fine on Rashida for each police wellness‑check call during Christopher’s parenting time unless the call resulted in Christopher’s arrest. Matters were continued; several proceedings (EOP hearing, temporary modification motion, rule to show cause) remained pending.

Record & Procedural Defects

- The appellate record lacked transcripts of the Feb. 26 proceedings. As appellant, Rashida bore the burden to provide a sufficient record; insufficient recordary doubts are resolved against the appellant. - The Feb. 26 order was entered in post‑dissolution proceedings. Under Illinois law, appeals ordinarily lie only from final judgments (Ill. Const. art. VI) unless an exception applies.

Jurisdictional Analysis

- Finality: Under Rule 304(a), a trial court must make an express written finding there is no just reason to delay enforcement or appeal for a non‑final single‑issue order to be immediately appealable. The Feb. 26 order contained no Rule 304(a) finding, and multiple related matters remained pending when Rashida filed her notice of appeal. - Interlocutory custody exception: Ill. S. Ct. R. 306(a)(5) allows a permissive appeal from interlocutory orders affecting care, custody, or allocation, but requires a timely petition for leave to appeal (filed within 14 days of the order). Rashida filed her notice of appeal on Mar. 26, 2025 — 28 days after the Feb. 26 order — and did not file a timely petition for leave under Rule 306(a)(5). - The court noted discretion exists to treat a notice of appeal as a petition for leave in narrow circumstances, but even that remedy would not cure the untimeliness here. - Precedent (In re Marriage of Crecos, Foutch, American Advisors Group v. Williams, and related authority) supports that post‑dissolution claims are treated as separate and that finality or proper Rule 306/304 compliance is required for appellate jurisdiction.

Holding / Disposition

The appellate court dismissed the appeal for lack of jurisdiction because Rashida failed to establish a final, appealable order under Rule 304(a) and failed to file a timely petition for leave under Rule 306(a)(5). No procedural or record deficiencies permitted the court to retain jurisdiction.

Administrative & Miscellaneous

Rule 23 notice: This order was filed under Supreme Court Rule 23 and is not precedent except as allowed by Rule 23(e)(1).

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