In re Parentage of L.G., 2019 IL App (1st) 180847-U

1. Case citation and parties
- In re Parentage of L.G., 2019 IL App (1st) 180847-U (1st Dist. Mar. 29, 2019).
- Petitioner-Appellant: Illinois Department of Healthcare & Family Services, ex rel. Nile C. (mother).
- Respondent-Appellee: Andrew G. (putative father). Child representative/Appellee: Marilyn Longwell.

2. Key legal issues
- Whether the trial court’s order directing that the minor child be vaccinated (and reserving further medical decision-making) was an appealable final order.
- Whether the vaccination order in effect re‑allocated parental responsibilities (parental decision‑making) such that it was subject to modification standards (change‑in‑circumstances) under the IMDMA/Parentage Act.
- Whether the order could be treated as an appealable injunction under Supreme Court Rule 307(a)(1).

3. Holding/outcome
- The appellate court dismissed the appeal for lack of jurisdiction. The challenged order was not an appealable final judgment under Supreme Court Rule 301 nor an allocation of parental responsibilities under Rule 304(b)(1), and it did not qualify as an appealable injunction under Rule 307(a)(1).

4. Significant legal reasoning
- Finality: A judgment is final if it disposes of the litigation or a definite part of it. The vaccination order left significant matters unresolved (reservation of future medical decision‑making; the pending relocation petition; other ongoing proceedings), so it was not final under Rule 301.
- Allocation vs. temporary UIFSA orders: Prior proceedings involved UIFSA and temporary child‑support orders; UIFSA generally does not allocate custody/parental responsibilities. The court reasoned the challenged order did not constitute a definitive allocation of parental responsibilities under Rule 304(b)(1). Nile’s argument that the child‑support order amounted to automatic allocation to the other parent was rejected as inapposite given the UIFSA/temporary nature of prior orders.
- Rule 307: The order’s passive phrasing (“[L.G.] be vaccinated”) did not clearly command a party to act; therefore it did not comfortably fit within injunction appealability. The court suggested the trial court should issue clearer, operative directions if it intends an enforceable command.

5. Practice implications
- Draft and enter clear, operative orders: If seeking an enforceable medical‑decision order, expressly allocate parental responsibilities or enter a clearly worded injunctive command identifying who must act and under what authority.
- Recognize jurisdictional limits: Appeals require finality or a statutory exception. Preserve appellate rights by seeking express allocation of parental responsibilities under the Parentage Act/IMDMA (so Rule 304(b)(1) applies) or by obtaining a clearly framed injunction.
- UIFSA caution: UIFSA proceedings are inappropriate fora for custody allocations; avoid relying on UIFSA/temporary support orders to effect parental‑responsibility reallocations.
- When seeking modification, plead and prove change of circumstances if relying on IMDMA standards; if not seeking modification, obtain an independent allocation order.