Adams v. Cuellar

2025 IL App (1st) 250134-U
CourtAppellate Court of Illinois
DecidedDecember 16, 2025
Docket1-25-0134
StatusUnpublished

This text of 2025 IL App (1st) 250134-U (Adams v. Cuellar) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Cuellar, 2025 IL App (1st) 250134-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 250134-U SECOND DIVISION December 16, 2025 No. 1-25-0134

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ JOSHUA ADAMS, ) Appeal from the Circuit Court ) of Cook County. Petitioner-Appellant, ) ) v. ) No. 19 D 79580 ) ERICA CUELLAR, ) Honorable ) Julie Aimen, Respondent-Appellee. ) Judge Presiding.

PRESIDING JUSTICE VAN TINE delivered the judgment of the court. Justices McBride and Ellis concurred in the judgment.

ORDER

¶1 Held: We affirm the circuit court’s grant of the majority of parenting time of minor daughter to respondent mother over petitioner father’s claims that the court erred in its application of the statutory best interests factors. 1-25-0134

¶2 Joshua Adams petitioned the circuit court of Cook County for majority parenting time of

his minor daughter, S.A., whom he fathered with respondent Erica Cuellar. 1 Joshua also requested

permission to relocate her to Kentucky (where he has lived throughout this litigation), arguing the

move would be in S.A.’s best interests. After years of litigation, the circuit court issued a written

order granting Erica the majority of parenting time. Joshua appeals that order. For the following

reasons, we affirm.

¶3 I. BACKGROUND

¶4 A. Rule 341(h)

¶5 At the outset, we note that neither party has provided this court with a sufficient statement

of facts. Illinois Supreme Court Rule 341(h)(6) required Joshua to include a statement of facts

“necessary to an understanding of the case, stated accurately and fairly without argument or

comment, and with appropriate reference to the pages of the record on appeal.” See Ill. S. Ct. R.

341(h)(6) (eff. Oct. 1, 2020). Although Joshua has included a “statement of facts” section in his

brief, he has barely set forth any facts, argued just as much in that section of his brief as in his

“argument” section, and failed to cite to the record on appeal and report of proceedings throughout.

These are clear violations of Rule 341(h)(6). See id. Our supreme court rules are

not mere suggestions; they have the force of law, and the parties must abide by them. Rosestone

Investments, LLC v. Garner, 2013 IL App (1st) 123422, ¶ 18. We have the inherent authority to

dismiss an appeal or strike a brief where a party’s brief does not comply with supreme court rules.

1 We acknowledge that, effective January 1, 2016, the phrases “allocation of parental responsibilities: decision making” and “allocation of parental responsibilities: parenting time” have replaced the phrase “custody” throughout the Illinois Marriage and Dissolution of Marriage Act. See Pub. Act 99-90, §§ 5-15 (eff. Jan. 1, 2016). As this change went into effect relatively recently, some decisions cited herein use the former nomenclature, but the substance of the law has not materially changed as it relates to the issues in this appeal.

2 1-25-0134

See North Community Bank v. 17011 South Park Avenue, LLC, 2015 IL App (1st) 133672, ¶ 14.

However, we recognize that doing so would be a harsh sanction. In re Detention of Powell, 217

Ill. 2d 123, 132 (2005). 2 Although the shortcomings of Joshua’s “statement of facts” section

needlessly complicate our review, we rely on the record on appeal (approximately 2700 pages)

and the report of proceedings (more than 2500 pages) in extracting the facts relevant to our

resolution of his appeal. In summarizing the circuit court’s orders throughout this litigation, we

relate only the portions of the orders germane to this appeal.

¶6 B. Motion Practice

¶7 Joshua and Erica met during one of Joshua’s work trips to Chicago in April of 2018. It

appears he was performing IT work at the medical office where Erica was employed. At all

relevant times, Erica has lived in the Chicago area and Joshua has lived in Lexington, Kentucky.

After a brief romantic relationship, S.A. was born on April 25, 2019. Joshua and Erica never

married or lived together. Erica allegedly began refusing Joshua’s calls after S.A.’s birth, and she

did not allow Joshua to see S.A. Thus, on May 21, 2019, Joshua filed a petition for allocation of

parental responsibilities in the circuit court of Cook County pursuant to the Parentage Act of 2015

(Parentage Act). See 750 ILCS 5/602 (West 2018).

¶8 The petition requested the court to determine parenting time and grant Joshua’s request to

relocate S.A. to his place of residence in Kentucky. Joshua alleged that Erica was an unfit mother

due to her depression and lack of financial resources to support S.A. He further alleged that he, on

the other hand, was gainfully employed and able to provide a stable and nurturing environment for

2 Erica’s statement of facts, which is only about two pages long, does not include all background information necessary to an understanding of the case, either. Although Rule 341 does not require the appellee (here Erica) to include a statement of facts, it would have been prudent to do so given the deficiencies of Joshua’s briefs.

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S.A. Accordingly, he requested the court to grant him the majority of parenting time, but he

remained amenable to sharing major decision-making authority equally with Erica regarding

S.A.’s education, health, religion, and extracurricular activities. Before the court ruled on that

petition, Joshua filed two more documents with the court.

¶9 On September 10, 2019, Joshua filed a petition requesting the court to appoint a guardian

ad litem (GAL) for S.A., citing “major concerns” over Erica’s ability to effectively parent their

minor child. On the same day, he filed a motion for temporary parenting time, citing similar

concerns and requesting either liberal parenting time or primary physical custody.

¶ 10 On September 11, 2019, Erica filed a petition requesting the allocation of the majority of

parenting time in her favor and requiring Joshua to contribute to child support, daycare, and her

attorney fees. As to parenting time, she alleged having a close and loving relationship with S.A.

and being her primary caretaker since birth. As to child support and daycare expenses, she alleged

that, although she was gainfully employed, she lacked sufficient income to support S.A. by herself.

Finally, Erica sought attorney fees incurred in the preparation of her petition.

¶ 11 On December 6, 2019, the parties appeared in court through counsel. The court ordered the

following: (1) Joshua to pay Erica $926 monthly in child support; (2) Joshua to pay Erica 50% of

daycare costs; (3) Erica to facilitate video calling three times per week between Joshua and S.A.;

(4) Erica to travel to Lexington, Kentucky (at Joshua’s expense) for a weekend and allow Joshua

eight hours of unsupervised parenting time with S.A. on Saturday and Sunday each; and (5) Erica

to facilitate Joshua’s access to S.A.’s medical care and daycare information. The court also set a

status hearing for January 28, 2020.

¶ 12 On December 23, 2019, Joshua filed four documents with the court. Joshua again

petitioned the court to appoint a GAL. He also filed a motion for a parenting evaluation under

4 1-25-0134

section 604.10(b) of the Illinois Marriage and Dissolution of Marriage Act (Marriage Act).

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Bluebook (online)
2025 IL App (1st) 250134-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adams-v-cuellar-illappct-2025.