Owens Sr. v. Related Management

Plaintiff, a former tenant evicted after a jury trial, filed a second pro se lawsuit against his former landlord and related individuals alleging breach of contract and wrongful eviction. The circuit court dismissed the complaint with prejudice under section 2-619(a)(4) as barred by res judicata following a 'full hearing,' and later denied a subsequent pleading construed as a motion to reconsider after another hearing, also denying plaintiff's request for a court reporter. Plaintiff appealed pro se from the denial of his motion to reconsider.

The appellate court affirmed on independent grounds. First, it found plaintiff's brief failed to comply with Illinois Supreme Court Rule 341(h)(7) because it offered only unsupported legal conclusions rather than a cohesive argument backed by citation to authority or the record—noncompliance that alone could justify dismissal, notwithstanding plaintiff's pro se status. Second, the court declined to consider documents attached to plaintiff's brief that were not part of the certified record on appeal, as such materials cannot supplement the record. Third, and most significantly, because plaintiff never obtained a court reporter, bystander's report, or agreed statement of facts documenting the hearings on the res judicata dismissal and motion to reconsider, the record was insufficient to evaluate any claimed error. Under longstanding Illinois precedent, the appellate court must presume the circuit court's judgment conformed with the law and had a sufficient factual basis when the record is incomplete.

The decision underscores the practical necessity of preserving an adequate record—including transcripts or approved substitutes—to challenge substantive rulings like res judicata dismissals, and reaffirms that pro se litigants are held to the same procedural standards as counsel.