Boolman v. Pohl

CourtAppellate Court of Illinois
DecidedJuly 8, 2026
Docket4-25-1140
StatusUnpublished

This text of Boolman v. Pohl (Boolman v. Pohl) 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
Boolman v. Pohl, (Ill. Ct. App. 2026).

Opinion

2026 IL App (4th) 251140-U NOTICE FILED This Order was filed under NO. 4-25-1140 July 8, 2026 Supreme Court Rule 23 and is Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

DOUGLAS MICHAEL BOOLMAN, ) Appeal from the Petitioner-Appellee, ) Circuit Court of v. ) Winnebago County CHRISTINE A. POHL, ) No. 25OP2260 Respondent-Appellant. ) ) Honorable ) Donald P. Shriver, ) Judge Presiding.

PRESIDING JUSTICE STEIGMANN delivered the judgment of the court. Justices Lannerd and Harris concurred in the judgment.

ORDER

¶1 Held: The appellate court concluded that respondent (1) forfeited appellate review of her claim that petitioner failed to lay a proper foundation for the admission of a cell phone recording and (2) failed to establish that her due process rights were violated because she could not see the recording during the hearing on petitioner’s petition for a no contact order.

¶2 Petitioner, Douglas Michael Boolman, filed a verified petition for a no contact

order against respondent, Christine A. Pohl. During a hearing on the petition, petitioner played a

video recording from a cell phone. Respondent did not object, and the trial court considered the

recording. The court granted the petition, and respondent filed a posttrial motion, arguing the no

contact order should be vacated because (1) no foundation was laid for the recording before it

was played and (2) she could not see the recording during the hearing. The court denied the

motion, and respondent appealed. We affirm.

¶3 I. BACKGROUND ¶4 Petitioner lived with Janet Rodriguez in a home next door to respondent’s house.

While they were neighbors, the parties had many disagreements about the property line between

their homes, such as whether respondent could keep her garbage cans on the property line and

whether petitioner could move the garbage cans to mow the area.

¶5 In the verified petition, which named petitioner and Rodriguez as protected

parties, petitioner alleged respondent (1) set off car alarms and beat on her trash cans early in the

morning to disturb and harass him and Rodriguez, (2) pushed a trash can against him and his

mower while he was mowing the grass at the property line, (3) yelled violent and degrading

things at him while he mowed his lawn, (4) threw rocks at his back and debris in front of the

mower while he mowed the grass, and (5) refused to keep her garbage cans solely on her

property. Petitioner asserted he had pictures and video recordings supporting his allegations.

¶6 At the hearing on the petition, respondent appeared via Zoom, and petitioner and

Rodriguez appeared in the trial court. During the hearing, the following exchange occurred:

“[PETITIONER]: I, I have these numbered, but—there is—there’s a

bunch of videos on there; pictures of the trash can and dates and, and all of them

show [respondent] accosting me.

(Whereupon a video was played in open court.)

MS. RODRIGUEZ: I, I had to hang up to call the police at that point and I

couldn’t tape any further.

[PETITIONER]: There’s, there’s a bunch of different videos. I, I had

numbered one through six.

THE COURT: I saw [respondent] pick up something in the video and

throw it at [petitioner].

-2- MS. RODRIGUEZ: You can hear the rock hit [petitioner’s] back.

THE COURT: All right. [Respondent], I’m going to show you this, as best

I can.

[RESPONDENT]: Okay. I think I probably know what it is but it was

[petitioner] putting a stick or throwing a stick my way and I threw one that

direction; I did not throw it at him. I can’t see it.

THE COURT: I can see it; you threw it at [petitioner].

[RESPONDENT]: I’m sorry.

THE COURT: I—your—

[RESPONDENT]: There’s no way I threw it at [petitioner].

THE COURT: —I’m done. I saw it.

[RESPONDENT]: Okay.” (Emphasis added.)

The video was not made part of the record on appeal.

¶7 The trial court granted petitioner’s petition, ordering respondent to stay 25 feet

away from petitioner and Rodriguez except under certain circumstances irrelevant to this appeal.

¶8 Within 30 days, respondent filed a posttrial motion, arguing, among other things,

the no contact order should be vacated because the recording was not authenticated and she

could not see the recording during the hearing. The trial court denied respondent’s motion.

¶9 This appeal followed.

¶ 10 II. ANALYSIS

¶ 11 On appeal, respondent, who proceeds pro se, argues the recording should not have

been admitted because (1) a proper foundation for its admission was not laid and (2) she could

not see the recording at the hearing. Putting aside the various problems with respondent’s brief,

-3- such as the fact that her argument contains no citations to the record and she fails to cite any

authority that would aid this court in deciding this appeal (see Ill. S. Ct. R. 341(h)(7) (eff. Oct. 1,

2020)), respondent’s arguments fail.

¶ 12 A. The Absence of an Appellee’s Brief

¶ 13 In resolving this appeal, we observe petitioner, the appellee, did not file a brief.

The supreme court has set forth three distinct discretionary options a reviewing court may

exercise in the absence of an appellee’s brief. See Thomas v. Koe, 395 Ill. App. 3d 570, 577

(2009). We may (1) serve as an advocate for the appellee and decide the case if we determine

justice so requires; (2) decide the merits of the case when the record is simple and the issues can

be easily decided without the aid of the appellee’s brief; or (3) reverse the trial court when the

appellant’s brief—namely, in the present case, respondent—demonstrates prima facie reversible

error that the record supports. Id. We will reverse the trial court only if respondent’s brief

establishes prima facie reversible error. “ ‘Prima facie’ means, ‘[a]t first sight; on first

appearance but subject to further evidence or information’ and ‘[s]ufficient to establish a fact or

raise a presumption unless disproved or rebutted.’ ” Id. (quoting Black’s Law Dictionary 1228

(8th ed. 2004)). With this in mind, we now turn to the merits.

¶ 14 B. Respondent Forfeited Her Foundation Objection to Petitioner’s Recording

¶ 15 Concerning respondent’s lack of foundation argument, we note the forfeiture rule

applies in cases involving the admission of a video recording. People v. Woods, 214 Ill. 2d 455,

470 (2005). Under the forfeiture rule, “both a trial objection and a written post-trial motion

raising the issue are necessary to preserve an issue for review.” People v. Enoch, 122 Ill. 2d 176,

186 (1988). Failure to do either results in forfeiture of the issue on appeal. Id. We review de novo

whether an issue is forfeited. People v. Gutierrez, 2024 IL App (2d) 230260, ¶ 34.

-4- ¶ 16 Here, respondent never objected to the admission of the recording when it was

played at the hearing. The requirement of a timely objection at the hearing was particularly

necessary because the “lack of a timely and specific objection deprive[d] the [petitioner] of the

opportunity to correct any deficiency in the foundational proof at the trial level.” Woods, 214 Ill.

2d at 470. Respondent simply cannot sit idly by and stand mute when the recording is offered at

the hearing and then object to its admission after the fact. See id. Accordingly, because

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Related

Foutch v. O'BRYANT
459 N.E.2d 958 (Illinois Supreme Court, 1984)
People v. Phyfiher
838 N.E.2d 181 (Appellate Court of Illinois, 2005)
People v. Woods
828 N.E.2d 247 (Illinois Supreme Court, 2005)
Thomas v. Koe
924 N.E.2d 1093 (Appellate Court of Illinois, 2009)
People v. Enoch
522 N.E.2d 1124 (Illinois Supreme Court, 1988)
In re Amanda H.
2017 IL App (3d) 150164 (Appellate Court of Illinois, 2017)
Carroll v. Department of Employment Security
907 N.E.2d 16 (Appellate Court of Illinois, 2009)
People v. Gutierrez
2024 IL App (2d) 230260 (Appellate Court of Illinois, 2024)

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Bluebook (online)
Boolman v. Pohl, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boolman-v-pohl-illappct-2026.