In re Marriage of Meyer-Fiedler

1. Case citation and parties
- In re Marriage of Meyer‑Fiedler, 2024 IL App (1st) 230458‑U (1st Dist. June 7, 2024) (Rule 23 order; non‑precedential).
- Petitioner‑Appellant: Dianne Meyer‑Fiedler. Respondent‑Appellee: Robert Fiedler.

2. Key legal issues
- Whether the trial court’s equitable distribution of marital property and assets was erroneous.
- Challenges to the contempt finding and purge amount for failure to comply with discovery/court orders.
- Allegations of fraud/ex parte communications and whether those void the trial court’s orders.
- Whether appellant’s procedural defects (failure to provide transcript/record; briefing rule violations) warrant affirmance.

3. Holding/outcome
- Affirmed. The appellate court upheld the dissolution judgment, denied relief from the contempt finding and fines, and affirmed Rule 137 sanctions against Dianne. The court concluded appellant failed to present an adequate record to show reversible error or fraud.

4. Significant legal reasoning
- Burden of record: The appellant failed to provide any report of proceedings or transcripts. Under Illinois appellate practice, the absence of a record of what occurred at trial generates a presumption that the trial court acted in conformity with the law; the appellant therefore could not show error.
- Briefing and appendix violations: Dianne’s opening brief violated Rules 341 and 342 (overlength, missing certificate of compliance, omitted statements of issues/jurisdiction/facts and required appendix items). Those procedural failures further undermined her appeal.
- Discretion and evidence: The trial court’s credibility findings (Robert credible; Dianne not credible), factual findings about undisclosed assets and conduct that diminished the marital estate, and the resulting property division were within the trial court’s discretion. The appellate court will not reweigh credibility or disturb discretionary property allocations absent an adequate record showing abuse.
- Unsubstantiated misconduct claims: Allegations of fraud and ex parte contacts were not supported by record evidence; bald assertions on appeal without preserved record do not void orders.

5. Practice implications (concise)
- Preserve the record: to challenge findings (property division, contempt, sanctions, alleged fraud or ex parte conduct) ensure transcripts, written motions, orders, and bills are in the record.
- Comply with appellate rules: adhere to Rules 341/342 (page limits, certificates, appendix contents) or risk waiver/dismissal or an adverse disposition.
- Document discovery compliance and valuation evidence: timely produce financial affidavits and documentary support for asset values to avoid contempt and credibility findings.
- If a litigant refuses to execute deeds/consents, seek judge’s deed/orders promptly and enforce them through contempt or execution mechanisms.
- Allegations of judicial or opposing‑counsel misconduct must be raised and developed below (motions, affidavits, hearings) to be reviewable on appeal.