In re Parentage of Keiaireyona Brown, 2019 IL App (1st) 182027‑U

1. Case citation and parties
- In re Parentage of Keiaireyona Brown, No. 1-18-2027 (Ill. App. Ct., 1st Div. Dec. 31, 2019) (Rule 23 order; non-precedential).
- Petitioner‑Appellant: Bridgette Pondexter n/k/a Bridgette C. Williams. Respondent‑Appellee: Moses Brown. Child: Keiaireyona Brown.

2. Key legal issues
- Whether the trial court erred in allocating post‑high‑school (college) expenses and in denying petitioner’s motion to reconsider.
- Whether the appellant was denied due process by the trial court’s handling of post‑judgment proceedings (including reopening proofs and consideration of an affidavit).
- Jurisdictional/timeliness issues surrounding successive post‑judgment motions and which order constitutes the final judgment for appeal.

3. Holding/outcome
- Affirmed. The appellate court upheld the trial court’s allocation (50% father, 25% mother, 25% child; with specific sums ordered) and denial of reconsideration. Appellate review was constrained by the appellant’s failure to provide transcripts of the challenged evidentiary hearings.

4. Significant legal reasoning
- Rule‑of‑record: absent transcripts of evidentiary hearings, appellate court must presume the trial court acted correctly and cannot meaningfully review factual findings or credibility determinations.
- Procedural/jurisdictional: because the trial court reopened proofs and heard testimony on Jan. 4, 2018, that order constituted the final judgment for appeal (not the earlier August 23, 2017 order). The appellant’s later “motion to correct” was treated on its substance as a timely post‑judgment motion.
- The court criticized appellant’s argumentative, unsupported statement of facts and emphasized that pro se status does not excuse noncompliance with Supreme Court Rules (Ill. S. Ct. R. 341(h)(6)). The daughter’s testimony (on the reopened proofs) undermined appellant’s claims; the trial court reasonably denied reconsideration.

5. Practice implications (concise)
- Always order and include transcripts of all evidentiary hearings you intend to challenge on appeal — failure is fatal to appellate review.
- Comply with Ill. S. Ct. R. 341(h)(6): provide a neutral, cited statement of facts; avoid argumentative assertions. Pro se status is no shield.
- Be aware that reopening proofs and receiving new evidence produces a new final order for appeal timing; labels of post‑judgment motions matter less than their substance.
- When contesting credibility findings, preserve the record (transcripts, exhibits) showing alleged errors; credibility determinations are notoriously deferential on appeal.