An Illinois appellate court vacated a sanction order against a pro se party for defying court orders by allegedly recording a Zoom hearing, concluding the lower court failed to instruct the defendant on steps to dissolve his contempt and recommended he be given a second chance.

In a Dec. 6 opinion, the Illinois First District Appellate Court vacated a Cook County Circuit Court's order finding defendant Cedric Robinson in civil contempt for recording Zoom court proceedings. The court vacated the trial court's order citing the lack of a purge provision, often described as "'the keys to the cell,'" which allows for the contemnor to know how to purge themselves from a civil contempt claim. Because the trial court failed to provide steps Robinson could take moving forward, the three-judge appellate panel remanded the ruling back to the lower court to enter an appropriate order, and, if necessary, commensurate with Robinson's conduct and due process rights. Justice Celia Gamrath authored the opinion and was joined by Justices Sanjay Tailor and Michael B. Hyman.