In re A.M., 179 N.E.3d 269

Parents Alicia C. and Lucas M. have twin daughters; a 2012 custody and visitation order gave Alicia custody and set Lucas’s alternating weekends, holiday, and two ten-day summer visits, plus information- and phone-access rights.
Lucas filed a petition under 750 ILCS 5/607.5 in June 2019 alleging Alicia interfered with parenting time and communications (dates alleged: Thanksgiving 2018, weekend of April 13, 2019, and summer 2019).
After hearings, the trial court found Alicia willfully violated the 2012 order, held her in indirect civil contempt, and ordered relief: 25 days of makeup parenting time (12 specified, 13 to be mutually scheduled), shared transportation, parent-education, possible counseling, and $2,934 in attorney fees.
Alicia appealed only the contempt finding, arguing the court should have treated the violations as criminal (because past acts cannot be purged) and that the order lacked an appropriate purge provision.
The appellate court held the §607.5 remedies (makeup time, counseling, education, fees) were authorized and affirmed those parts, but vacated the portion of the order finding Alicia in indirect civil contempt because the order contained no proper purge mechanism or coercive sanction.

Issue	Alicia's Argument	Lucas's Argument	Held
Whether contempt should be civil or criminal	Past violations cannot be undone; contempt must be criminal	Civil contempt proper; order imposes obligations that can coerce compliance; §607.5 relief stands	Court: same conduct can justify either; here civil contempt finding not sustainable but not because past conduct per se requires criminal treatment
Whether order contained an adequate purge provision	Order lacks purge provision; cannot purge past acts	Order included definite obligations (including makeup dates) giving ability to purge	Vacated civil contempt: purge provision absent or improper because required third-party cooperation, not solely contemnor action
Whether remaining §607.5 relief was authorized	Vacating contempt should void entire order	Even if contempt vacated, relief authorized by §607.5 is proper	Affirmed: makeup time, counseling, education, fees authorized under §607.5 and upheld
Appellate jurisdiction over contempt finding despite no sanctions	(implicit) challenge to validity of contempt order	The §607.5 order disposed of the petition and was final and appealable	Court had jurisdiction: contempt finding was part of a final §607.5 order

People v. Warren, 173 Ill.2d 348 (discusses court's inherent contempt power and civil vs criminal contempt distinction)
In re Marriage of Betts, 200 Ill. App.3d 26 (articulates test for civil vs criminal contempt and dominant-purpose inquiry)
Felzak v. Hruby, 226 Ill.2d 382 (civil contempt is coercive and intended to compel future compliance)
In re Marriage of Logston, 103 Ill.2d 266 (civil contemnor must be given the "keys to his cell"—a means to purge contempt)
People v. Covington, 395 Ill. App.3d 996 (civil-contempt sanctions must cease upon compliance; minimal due-process standard explained)
Bank of America, N.A. v. Freed, 971 N.E.2d 1087 (purge provisions are improper if they leave lifting sanctions to a third party)