In re Marriage of Winston, 2020 IL App (1st) 191007‑U

1. Case citation and parties
- In re Marriage of Winston, No. 1‑19‑1007 (1st Dist. Sept. 30, 2020) (Rule 23 order; non‑precedential).
- Petitioner‑Appellant: Camille Winston. Respondent‑Appellee: Trumane Hampton.

2. Key legal issues
- Whether a trial court’s temporary order (entered during a contempt/status hearing) that transferred residential placement to the father was properly before the appellate court.
- Whether the trial court’s final judgment allocating parental responsibilities (adopting the parties’ agreed parenting plan) was against the manifest weight of the evidence.

3. Holding / outcome
- Affirmed. The appellate court held: (1) the temporary order was not properly before the court because appellant failed to file a petition for leave to appeal (and, in any event, the temporary order was moot because superseded by the final allocation judgment); (2) the final allocation of parental responsibilities was not against the manifest weight of the evidence—the court permissibly adopted the parties’ agreed parenting plan as being in the child’s best interest.

4. Significant legal reasoning
- Appealability / mootness: The court emphasized procedural requirements for challenging interlocutory custody‑type relief and noted the temporary order was effectively superseded by the later final allocation order, rendering review of the temporary order moot.
- Standard of review and best‑interest determination: The trial court appointed a guardian ad litem, considered the parenting agreement reached by the parties, and entered a final allocation. Under the manifest‑weight standard, the appellate court will not disturb a parental‑responsibility decision where the record shows a reasoned best‑interest determination or where the parties’ agreement supports the outcome. The appellant failed to identify record evidence sufficient to overcome that deferential review.

5. Practice implications (concise)
- Interlocutory custody/placement orders: promptly preserve appellate rights—file any required petition for leave to appeal and perfect the record; otherwise the issue may be dismissed or deemed unreviewable.
- Mootness risk: temporary orders are often superseded by final judgments; attack temporary rulings quickly or seek immediate appellate relief.
- Agreed parenting plans: courts commonly adopt agreed plans if supported as being in the child’s best interest; appellate relief is difficult under the manifest‑weight standard.
- Record and findings: preserve objections, seek on‑the‑record findings addressing statutory best‑interest factors (750 ILCS 5/602.7), and ensure transcripts/orders are complete (including orders of protection/paternity) to support appellate review.
- Note: This is a Rule 23 (non‑precedential) disposition with limited citation value.