Quinn
Key Insights
Reversal Rate
100%
Case History
5 Cases
Case Outcomes
Recent Decisions
In re Marriage of Bartlett
- Case citation and parties In re Marriage of Bartlett, 2024 IL App (1st) 230624-U (1st Dist. Oct. 30, 2024) (Rule 23 non‑precedential). Counter‑petitioner/Appellant: Dennis M. Quinn. Counter‑respondent/Appellee: Lynne E. Bartlett. - Key legal issues 1. Whether a former spouse’s voluntary retirement can constitute a substantial change in circumstances warranting modification of permanent maintenance (addressed in prior appeal, Quinn I). 2. On remand, whether the trial court properly set monthly maintenance (including deviation from statutory guideline) under 750 ILCS 5/504(a) and 5/510(a‑5). 3. Whether Quinn was entitled to reimbursement for maintenance paid post‑retirement or otherwise to require repayment by Bartlett (credit/offset issues). - Holding / outcome The appellate court affirmed. On remand the trial court permissibly deviated from the guideline (which produced $0) and set permanent maintenance at $807.78 per month (above guideline). The court also ordered that Quinn receive a credit for the maintenance he overpaid retroactive to his retirement; the parties were directed to compute the precise amount. Duration remained indefinite; each party bears their own fees. - Significant legal reasoning (concise) The court applied Sections 504 and 510, concluding that a guideline result of $0 did not foreclose an upward deviation in a permanent‑maintenance context. The court considered: parties’ ages and long marriage; earning capacity and work history (Quinn retired after a long legal career; Bartlett has significant medical disabilities and limited earning capacity despite professional credentials); income, assets, debts, and liquidity (stipulated asset totals and prior gifts); monthly expense disparities (Bartlett’s expenses consumed a larger share of combined monthly outlays); and retirement realities (mandatory IRA distributions/SS). Given those factors, the court found deviation appropriate to address inequity despite guideline calculations. On overpayment, the trial court recognized Quinn’s entitlement to a credit (rather than full immediate reimbursement), ordering computation but preserving prior offsets (e.g., Social Security-related credits). - Practice implications - After Quinn I, voluntary retirement can be a substantial change; counsel should document timing, motivation, earnings loss, gifts/transfers, and retirement planning. - Even if guideline maintenance computes to zero, courts may deviate upward in permanent maintenance cases — emphasize health, expenses, earning capacity, and asset liquidity. - Seek explicit rulings on credits/retroactivity and computation methodology when overpayments occur; courts may award credits rather than full reimbursement and preserve prior offsets. - Preserve detailed financial exhibits and stipulations; litigate (or settle) treatment of SS, IRA RMDs, and inter‑spousal transfers.
In re Marriage of Bartlett
- Case citation and parties In re Marriage of Bartlett, 2022 IL App (1st) 201358‑U (1st Dist. Mar. 17, 2022). Counter-respondent/Appellee: Lynne E. Bartlett. Counter-petitioner/Appellant: Dennis M. Quinn. - Key legal issues 1. Whether a former husband’s drop in earned income caused by voluntary retirement constitutes a “substantial change in circumstances” under Section 510 of the Illinois Marriage and Dissolution of Marriage Act so as to permit modification or termination of post‑dissolution maintenance. 2. Whether the trial court abused its discretion in ordering the husband to pay the wife’s attorney fees in full. - Holding/outcome The appellate court affirmed in part, reversed in part, and remanded. It held the trial court erred in finding that Quinn’s decreased income from voluntary retirement did not constitute a substantial change in circumstances warranting modification of maintenance. The court affirmed the trial court’s award obligating Quinn to pay Bartlett’s attorney fees (approximately $73,271.09) in full. The matter was remanded for further proceedings consistent with the opinion. - Significant legal reasoning (concise) The court emphasized that a voluntary retirement that materially reduces a payor’s income can amount to a substantial change in circumstances under Section 510 — it is not categorically disallowed simply because retirement was voluntary. The appellate court distinguished the standards for terminating vs. modifying maintenance and found the trial court improperly conflated them (the trial court had granted a directed finding as to termination but denied modification). The record showed a significant decline in Quinn’s earned income after retirement, ongoing retirement and investment assets (including required minimum distributions), Social Security receipts, past maintenance payments, mortgage obligations, gifting to children, and the wife’s limited earning capacity and assets. Those facts require the trial court to reassess maintenance under the statutory framework rather than refuse modification solely because the payor’s retirement was voluntary. As to attorney fees, the appellate court found the trial court acted within its discretion: the fee award was supported by the parties’ relative resources, the wife’s need, and the reasonableness of fees documented in the record. - Practice implications (brief) - Voluntary retirement is not per se a bar to modification; litigants must develop a full record on income before/after retirement, assets (including IRAs/RMDs), Social Security, gifts, and lifestyle. - Separate analyses are required for termination versus modification; counsel should address intent to evade obligations and reasonableness of retirement timing. - When seeking fee awards, document need and reasonableness and emphasize disparity in resources and the client’s limited ability to pay. - Expect remands for recalculation when appellate courts find the trial court misapplied the Section 510 substantial‑change inquiry.
Other 1st District Judges
Frequently Asked Questions
What is Quinn's overall affirm rate on family law appeals?
Quinn has an overall affirm rate of 0% across 5 family law cases reviewed.
Which Illinois appellate district does Quinn serve in?
Quinn serves in the Illinois 1st District Appellate Court.
How often are Quinn's decisions reversed on appeal?
Quinn has a 100% reversal rate, with 5 decisions reversed out of 5 total cases.
Need Strategic Insights for Your Appeal?
Get deeper analytics, outcome forecasts, and compare judges side-by-side with a Professional subscription.
Upgrade to Professional