Appeal ends; court order not yet final

Trial Notebook

By Steven P. Garmisa

Hoey & Farina

Posted June 7, 2016 2:44 PM

An appeal from a final order during third-party citation proceedings to collect on a money judgment is appealable under Illinois Supreme Court Rule 304(b)(4) — even if there are ongoing collection efforts and an interlocutory appeal has not been authorized via a special finding under Rule 304(a).But jurisdiction for appeals under Rule 304(b)(4) is sometimes murky, because “few cases discuss which orders in supplementary proceedings are final orders.” PNC Bank v. Hoffman, 2015 IL App (2d) 141172.In a new …

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