In re Parentage of N.N., 2023 IL App (1st) 221544-U

- Case citation and parties
In re Parentage of N.N., 2023 IL App (1st) 221544-U (1st Dist. Mar. 17, 2023) (Rule 23 order). Petitioner-Appellant: Andre N.; Respondent-Appellee: Nya P. (Appeals Nos. 1-22-1544 & 1-22-1612).

- Key legal issues
1) Whether the trial court properly entered a plenary order of protection against petitioner (challenge in 1-22-1544).
2) Whether various subsequent interlocutory orders — including indirect contempt for failure to pay attorney’s fees and child support and an order requiring a psychological evaluation — were appealable and subject to reversal (issues in 1-22-1612).
3) Numerous collateral requests for extraordinary relief (writs of prohibition/mandamus, sanctions, vacation of orders, reinstatement of a 2016 parenting plan).

- Holding / outcome
The appellate court affirmed the trial court’s grant of the plenary order of protection (appeal 1-22-1544). The remaining challenges (1-22-1612), including attacks on contempt and fee/psych evaluation orders and the many collateral requests, were dismissed for lack of appellate jurisdiction because the orders challenged were not final. The court considered the appeals despite no appellee brief (First Capitol v. Talandis).

- Significant legal reasoning (concise)
The panel treated the plenary protective order as appropriately reviewable and affirmed it on the merits. By contrast, the court held that many of petitioner’s complaints related to nonfinal, interlocutory rulings — and thus were not properly before the appellate court as direct appeals. The opinion emphasizes final-judgment jurisdictional limits: interlocutory orders and piecemeal challenges (including contempt and fee enforcement steps) must generally await a final appeal or be challenged via proper extraordinary remedies. The decision is filed under Ill. S. Ct. Rule 23 and is not precedent except in limited circumstances.

- Practice implications for family-law attorneys
- Protective orders: plenary protective orders remain subject to normal appellate review and can be affirmed even where the respondent (here, petitioner) pursues extensive collateral challenges. Trial-court findings supporting protection orders should be carefully preserved in the record.
- Jurisdictional caution: counsel should avoid piecemeal appeals of interlocutory family-court rulings. If immediate relief is required, seek appropriate interlocutory relief (e.g., leave to appeal, supervisory writs) rather than a direct appeal of nonfinal orders.
- Pro se/litigation management: repeated pro se filings and collateral attacks are unlikely to succeed and may be admonished; courts will enforce orders (support, evaluations) and may find contempt for noncompliance.
- Appellate strategy: when opposing a pro se appellant, courts may proceed under First Capitol when no appellee brief is filed; ensure the trial record supports interlocutory orders or obtain finality before appeal.