Legal Memorandum: Appellate Jurisdiction on issues raised after initial ruling

Issue: Under Illinois law, may a party challenge an issue on appeal that was not raised in the court below?

The court lacks jurisdiction to consider [any party’s] challenge of a ruling that does not appear in the record [prior to appeal]. Canel and Hale, Ltd. v. Tobin, 304 Ill. App. 3d 906, 921 (1999) (citing Goodrich v. Sprague, 376 Ill. 80, 86 (1941) (appellate court jurisdiction extends only to those matters in controversy which have been ruled upon by the trial court).