In re Parentage of D.L., 2020 IL App (1st) 171816-U

1. Case citation and parties
- In re Parentage of D.L., 2020 IL App (1st) 171816-U (1st Dist. Nov. 24, 2020) (Rule 23 order; nonprecedential).
- Petitioner: D.L. (mother). Respondent: C.S. (putative father). Names replaced with initials by Illinois Supreme Court supervisory order.

2. Key legal issues
- Whether the trial court’s June 30, 2017 order modifying child support was a final, appealable judgment.
- Whether the appellate court had jurisdiction where related motions/petitions remained pending and no Supreme Court Rule 304(a) finding was entered.

3. Holding/outcome
- Appeal dismissed for lack of jurisdiction. The appellate court concluded the order was not final and, alternatively, even if final, unresolved claims existed and no Rule 304(a) finding had been made.

4. Significant legal reasoning (condensed)
- Finality requirement: Under Supreme Court Rules 301/303 and settled Illinois precedent, appellate jurisdiction exists only for final judgments (or where rule exceptions apply). A final judgment must determine the litigation on the merits or a definite part thereof so the only remaining step is enforcement.
- The June 30, 2017 order was not final because it left key matters unresolved and necessary for enforcement: (a) an account adjustment review to determine alleged overpayments/retroactive offsets; (b) entry of a uniform support order specifying payment frequency, termination, enforcement details; and (c) protocols for reporting and enforcing support based on bonuses and restricted stock unit (RSU) awards. Without those details the award was not fully enforceable or reviewable. The court relied on comparison to cases (e.g., Capitani) holding that unresolved essential details prevent finality.
- Rule 304(a) alternative: Even if the modification order had been treated as final, there were multiple pending motions/petitions at the time the notice of appeal was filed (sanctions, show-cause motions, etc.), and the trial court did not make the required written finding under Rule 304(a) that there was no just reason to delay appeal. That omission independently deprived the appellate court of jurisdiction.

5. Practice implications (practical takeaways for attorneys)
- Do not appeal partial/support orders that leave enforcement details unfinished (uniform order, reporting protocols, account adjustments) without a Rule 304(a) finding.
- Before filing an appeal, move in the trial court to: (a) enter a complete uniform order with enforcement mechanics; (b) resolve account adjustment/overpayment claims or obtain a stay; (c) set clear protocols for bonuses/RSUs and how they’ll be imputed/collected.
- If some claims remain, obtain an express written Rule 304(a) finding to preserve appeal rights.
- Preserve a complete record of underlying proceedings and ensure ancillary motions are resolved or expressly waived before appealing.