In re Marriage of Bean-Oyler

Case

In re Marriage of Heather M. Bean‑Oyler and Zachary M. Oyler, Ill. App. Ct., 4th Dist., No. 4‑25‑0319 (Nov. 6, 2025) (Rule 23 order). Panel: Justice Zenoff (delivered); Presiding Justice Harris and Justice DeArmond (concurred).

Procedural Posture

Appeal from Peoria County (No. 22DN254). Appellant: Heather M. Bean‑Oyler; Appellee: Zachary M. Oyler. Final judgment entered Dec. 9, 2024; motion to reconsider denied Feb. 28, 2025.

Issues

- Did the trial court err by failing to calculate and state the statutory guideline amount of maintenance before departing from it? - Did the court abuse its discretion by allocating most marital debt to Zachary rather than awarding periodic maintenance to Heather? - Was awarding the marital residence to Zachary (rather than ordering sale and splitting proceeds) improper given the lack of an appraisal?

Key Facts

Marriage 2012–dissolution filed 2022. Zachary: variable, relatively high income (2024 year‑to‑date shown ~ $256k; prior years variable); Heather: minimal earned income at trial, received substantial temporary maintenance payments (Jan–Aug 2024: ~$79,423) and a wrongful‑death settlement (about $75,000 remaining). Marital estate heavily indebted (total debts in record > $550k); Bigelow residence valuations disputed ($225,000 v. $340,000) with no appraisal.

Holding

The appellate court reversed in part and remanded. The trial court failed to comply with the statutory requirement to state the maintenance amount (or the guideline figure that would apply) before deviating from the guidelines (750 ILCS 5/504(b‑2)(2)); because no guideline amount can be derived from the record, meaningful review of the deviation is impossible. The court therefore remanded for the trial court to calculate and state the guideline maintenance amount and to re‑evaluate maintenance and property/debt apportionment in light of that finding. Concurrently, the court held that (1) the Dissolution Act permits allocating marital debt in lieu of awarding maintenance (750 ILCS 5/503(d)(10)), so assigning debt to one spouse is not per se improper, and (2) the trial court did not abuse its discretion in awarding the marital residence to Zachary when neither party produced competent valuation evidence—parties cannot complain on appeal of a valuation they failed to prove. Those aspects of the judgment were not reversed.

Reasoning (concise)

- Statutory mandate: when guideline maintenance is applicable, the court must state the amount or the duration that would have applied under the guidelines and explain any variance. The trial court here computed a guideline duration (4 years, 7 months) but did not calculate or state the guideline amount and made no net‑income findings from which the guideline figure could be derived. That omission violated the statute (or at least required substantial compliance) and prevented appellate review of the deviation where the court offset maintenance by allocating debt. - On property/debt allocation: section 503(d)(10) allows considering whether an apportionment is in lieu of maintenance; Illinois precedent supports awarding assets or assigning debts as the functional equivalent of support in appropriate cases. - On valuation of the residence: valuation cannot rest on unsupported testimony; if neither party submits competent evidence, the court may divide property without a specific valuation and is not required to order a sale. Because Heather had the opportunity but did not present foundation or expert proof, the trial court’s award of the house to Zachary was not an abuse of discretion.

Disposition / Remand Instructions

Reversed in part and remanded with directions: the trial court must (1) determine and state the specific maintenance amount that would apply under the statutory guidelines (and explain any deviation), and (2) re‑evaluate its maintenance award and the division/allocation of marital assets and debts in light of that guideline figure. On remand the court may receive competent valuation evidence for the marital residence, order its sale and division of proceeds, or otherwise adjust the property/debt allocation to effect a just result consistent with the opinion.

Practical Point

Failure to present net‑income or proper valuation evidence at trial limits appellate relief on those discrete issues, but a trial court’s omission of a statutorily required guideline maintenance calculation necessitates remand so the record permits review of any deviation.