In re Marriage of Hainds, 2025 IL App (4th) 250454‑U

1) Case citation and parties
- In re Marriage of Hainds, No. 4‑25‑0454, 2025 IL App (4th) 250454‑U (Ill. App. Ct. 4th Dist. Nov. 7, 2025) (Rule 23 order; non‑precedential).
- Petitioner‑Appellee: Russell L. Hainds. Respondent‑Appellant: Sonia L. Hainds. Sonia appealed pro se from an order finding her in indirect civil contempt for failing to refinance the marital home as required by the dissolution judgment.

2) Key legal issues
- Whether the trial court abused its discretion by excluding certain documentary evidence.
- Whether the court misinterpreted prior orders (scope of Sonia’s refinancing obligation).
- Whether imposing a 60‑day deadline to refinance or list the property constituted an abuse of discretion.
- Whether the court showed judicial bias or failed to adjudicate issues raised at the hearing.
- Whether the contempt finding was supported where Sonia later paid off the mortgage (purge).

3) Holding / outcome
- The appellate court affirmed. It held Sonia’s appellate claims were moot, forfeited, or without merit, and the trial court acted within its discretion. The contempt finding and remedial deadlines were upheld; the record showed Sonia subsequently purged the contempt by paying off the mortgage.

4) Significant legal reasoning
- The dissolution judgment expressly required Sonia to “make reasonable efforts” to refinance by Aug. 31, 2012, and every six months if denied. The 2012 agreed order also contemplated continued attempts. The trial record showed Sonia made only sporadic, informal “soft‑pull” inquiries, never submitted applications, and used tax refunds and other funds for living expenses rather than to eliminate the mortgage. Documentary evidence she sought to admit either lacked proper foundation (undated “denial” letters) or was irrelevant to issues before the court; the trial court’s evidentiary rulings were reasonable. Claims that the court misread orders or was biased were either not preserved or unsupported. The contempt was civil and coercive — the court gave a purge remedy (refinance or list within 60 days) — and Sonia cured contempt by paying off the loan; that outcome does not render the trial court’s prior contempt finding erroneous.

5) Practice implications (short)
- Enforcement: Courts will enforce affirmative refinancing obligations in dissolution judgments and may use civil contempt with purge terms to compel performance.
- Evidence: Proffers of documentary denials/refusals require proper foundation (dates, authentication); pro se litigants should be cautioned about foundational rules.
- Preservation: Failure to make specific objections or to develop the record forfeits appellate review.
- Remedies: Contempt remains an effective, discretionary tool; post‑order purges will remedy sanctions but do not negate the propriety of enforcement.
- Procedural: This is a Rule 23, non‑precedential opinion — persuasive but not binding.