City of Chicago v. Gipson, 2022 IL App (1st) 210071-U

City of Chicago filed housing-code enforcement actions against owners of 5415 W. Rice St. for conditions rendering the property unsafe; Agwu Mong was added as a purported agent/manager.
A receiver was appointed to restore heat/water and manage the property; the receiver filed interim accountings and requested receiver’s certificates.
Mong filed an eviction action against upstairs tenants; the housing cases were consolidated and remained pending with the receiver continuing management for years.
On December 3, 2020 the circuit court entered three orders: two approving the receiver’s third and fourth interim accountings (and authorizing receiver’s certificates) and a third denying Mong’s motion to dismiss, purging a contempt order, setting inspection/management dates, and scheduling further hearings.
Mong appealed pro se from the December 3, 2020 orders; the City declined to file an appellee brief.
The appellate court dismissed the appeal for lack of jurisdiction, holding the challenged orders were interlocutory/nonfinal and Mong failed to present a sufficiently complete record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the December 3, 2020 orders approving interim receiver accountings final and appealable under Rule 301?	The orders are interim/nonfinal and therefore not appealable.	Mong treated the accounting approvals as final and appealed under Rule 301.	Not appealable; appellate court lacked jurisdiction.
Is the denial of Mong’s motion to dismiss a final, appealable order?	Denial of a motion to dismiss is interlocutory and not final.	Mong sought immediate review and asked the court to dismiss the cases.	Denial is interlocutory; not appealable.
Did Mong provide a sufficient record to support appellate review?	Mong failed to include key filings and omitted case records; appellant bears burden of complete record.	Mong submitted a limited record and brief, arguing the errors are evident.	Mong failed his burden; incomplete record precludes relief.
Should interim receiver-accounting orders be reviewed piecemeal on appeal?	Allowing appeals from interim accountings would cause piecemeal litigation and delay; Rule 301 discourages such appeals.	Mong argued alleged receiver enrichment and requested reversal/adjustment of accountings.	Court emphasized policy against piecemeal appeals and refused to exercise jurisdiction.

First Capitol Mortgage Corp. v. Talandis Construction Corp., 63 Ill. 2d 128 (1976) (appellate court may decide appeal without appellee brief if record/simple)
Flores v. Dugan, 91 Ill. 2d 108 (1982) (definition of final judgment)
Marsh v. Evangelical Covenant Church of Hinsdale, 138 Ill. 2d 458 (1990) (order must resolve every right, liability or matter raised to be final)
EMC Mortgage Corp. v. Kemp, 2012 IL 113419 (2012) (generally appellate courts lack jurisdiction to review interlocutory orders)
Walker v. Carnival Cruise Lines, Inc., 383 Ill. App. 3d 129 (2008) (denial of motion to dismiss is interlocutory)
Desnick v. Dep’t of Professional Regulation, 171 Ill. 2d 510 (1996) (same)
In re Marriage of Tetzlaff, 304 Ill. App. 3d 1030 (1999) (discussion discouraging interim-fee appeals to prevent piecemeal appeals)