In re Marriage of Allen, 2021 IL App (4th) 200363-U

1. Case citation and parties
- In re Marriage of Allen, 2021 IL App (4th) 200363-U (Ill. App. Ct., 4th Dist. June 21, 2021) (Rule 23 order, nonprecedential).
- Petitioner-Appellee: Melissa A. Allen. Respondent-Appellant: Rickey D. Allen Jr.

2. Key legal issues
- Whether the trial court erred by (a) ordering respondent to reimburse half of a child’s orthodontic expense and (b) excluding respondent’s exhibits at a hearing on petitioner’s declaratory judgment motion interpreting the marital settlement agreement (MSA) allocating uncovered medical/orthodontic expenses.

3. Holding/outcome
- Affirmed. The appellate court upheld the trial court’s partial grant of petitioner’s declaratory-judgment motion: respondent ordered to reimburse one-half of Preston’s braces ($4,595.44; respondent’s share $2,297.72, payable $250/month by withholding) and both parties required to split one-half of Laella’s uncovered medical/orthodontic expenses. The trial court also granted respondent’s motion to terminate child support for Preston upon his turning 18, if support was current.

4. Significant legal reasoning
- The court disposed of the appeal primarily on procedural grounds: appellant failed to provide a transcript, bystander’s report, or agreed statement of facts for the July 6, 2020 hearing where evidence and testimony were presented. Under Foutch and related authority, absence of a complete record leads to a presumption the trial court’s order conforms with law and has a sufficient factual basis.
- The court emphasized appellant’s additional failure to present reasoned argument or cite authorities as required by Illinois Supreme Court Rule 341; bare contentions are forfeited.
- The opinion restated relevant standards: declaratory relief is authorized by 735 ILCS 5/2‑701; factual and credibility findings are reviewed for manifest-weight deference (de novo only as to nonfact-based conclusions); admissibility rulings reviewed for abuse of discretion (Peach v. McGovern). Because the record was incomplete and briefing inadequate, the appellate court declined to reach the merits.

5. Practice implications (concise takeaways for practitioners)
- Preservation: Always secure a transcript or prepare an agreed statement/bystander’s report per Ill. S. Ct. R. 323 when contesting evidentiary rulings or factual findings.
- Briefing: Comply strictly with Rule 341—developed argument, citations to record and authority—or risk forfeiture. Pro se status does not excuse noncompliance.
- Declaratory relief: Use 735 ILCS 5/2‑701 to seek construction of MSA terms; courts will defer to trial findings if the record supports them.
- Evidentiary challenges: Preserve objections at trial and in the record to enable appellate review of admissibility decisions.