In re Marriage of Bean-Oyler

1. Case citation and parties
- In re Marriage of Bean-Oyler, No. 4-25-0319, 2025 IL App (4th) 250319-U (Ill. App. Ct. 4th Dist. Nov. 6, 2025).
- Petitioner-Appellant: Heather M. Bean‑Oyler. Respondent‑Appellee: Zachary M. Oyler.

2. Key legal issues
- Whether the trial court complied with the statutory requirement to calculate and state the guideline maintenance amount before deviating from the guidelines.
- Whether the court properly used allocation of marital debt and disposition of the marital home (awarding home to husband rather than sale) in lieu of awarding maintenance.
- Whether the property division and debt allocation were supported by adequate findings in light of maintenance determinations.

3. Holding / outcome
- Reversed and remanded. The appellate court held the trial court erred by failing to state the amount of maintenance the wife would have been entitled to under the statutory guidelines before deviating from those guidelines. The court remanded for the trial court to calculate and specify the guideline maintenance amount and to reevaluate maintenance and the property/debt division in light of that calculation.

4. Significant legal reasoning
- The Fourth District emphasized the statutory mandate that a trial court must determine and state the guideline maintenance amount before imposing any deviation. That procedural/calculational step is necessary to permit meaningful appellate review of whether a deviation is justified.
- Although the trial court made extensive factual findings (education, employability, health, standard of living, creditors/tax liabilities, contributions, and who was primary breadwinner), the appellate court found the omission of the guideline calculation alone required reversal.
- The opinion focused on process: because the trial court allocated most marital debt to husband and awarded him the marital residence (apparently in lieu of maintenance), the absence of a baseline guideline figure prevented an assessment whether the deviation was reasonable or adequately explained.

5. Practice implications (concise)
- Preserve the guideline calculation on the record. If asking a court to deviate (or to offset maintenance by allocating debt/awarding property), require the court to announce the guideline maintenance amount and show its arithmetic before explaining any deviation.
- When debt allocation or awarding an in‑kind asset is relied on to offset maintenance, obtain express findings quantifying how that allocation equates to maintenance relief.
- When the marital residence is the principal asset, litigants should press for appraisals, present valuations and cash‑flow projections (tax consequences, mortgage payoff, liquidity) and request express findings on sale vs. in‑kind award.
- Preserve motions/request for written findings (and proposed calculations) to facilitate appellate review.