Graham v. Rengen

Respondent appealed from the trial court’s extension of two plenary orders of protection entered against her, arguing that the petitioners failed to demonstrate “good cause” for the extensions. Respondent also argued that the orders should be vacated because the report of proceedings and the trial court’s written orders did not contain the statutory findings required by section 214(c)(1) of the Illinois Domestic Violence Act. The appellate court affirmed, finding that the trial court’s decision to extend the plenary orders of protection for an additional two years was not against the manifest weight of the evidence where the record supported a finding that respondent’s conduct constituted “abuse” as that term was defined by the Act. The appellate court also declined to remand the cause solely for the purpose of requiring the trial court to expressly state in a written order that it had considered the relevant statutory factors. (McLAREN and JORGENSEN, concurring)