Mehalko v. Doe

Illinois Appellate Court
Civil Court
Jurisdiction
Citation
Case Number: 
2018 IL App (2d) 170788
Decision Date: 
Tuesday, July 10, 2018
District: 
2d Dist.
Division/County: 
Winnebago Co.
Holding: 
Affirmed and remanded.
Justice: 
SPENCE

Court erred in failing to include a purge provision in its Rule 219 order of postjudgment sanctions, which is required for indirect civil contempt. Although motion for contempt was filed more than 30 days after judgment, contempt powers of court provided it with jurisdiction to hear petition and impose sanctions. Rule 219 allows a trial court to enforce its discovery orders through contempt proceedings. (HUDSON and SCHOSTOK, concurring.)