In re Marriage of Bachinadanda, 2021 IL App (1st) 020576‑U

1) Case citation and parties
- In re Marriage of Belliappa Nanaiah Bachinadanda (Petitioner‑Appellee) and Ponnamma Nanaiah Bachinadanda (Respondent‑Appellant), No. 1‑20‑0576 (Ill. App. Ct. 1st Dist. May 26, 2021) (Rule 23 order).

2) Key legal issues
- Whether the trial court abused discretion in excluding: (a) psychological evaluation reports (Sup. Ct. Rule 215), (b) an immigration attorney as a witness (disclosure/Sup. Ct. Rule 213), and (c) subpoenas issued after close of discovery.
- Whether the trial court erred in denying the mother’s petition to relocate children to India (best‑interest/relocation factors).
- Whether the court erred in division of marital estate, maintenance (spousal support), and allocation of GAL fees.
- Jurisdiction/timeliness of appeal (notice of appeal filed within 30 days of denial of post‑trial motions).

3) Holding / outcome
- Affirmed in all respects. Motion to dismiss appeal denied; appellate court found it had jurisdiction. Trial court did not err in evidentiary rulings, denial of relocation, or property/support orders. Appellant’s claims were rejected.

4) Significant legal reasoning (concise)
- Evidentiary exclusions were affirmed as within the trial court’s discretion. The parties had agreed to psychological testing but defense counsel did not receive the reports until shortly before trial; the court found noncompliance with Rule 215 (timely distribution) and barred the reports. Subpoenas issued after discovery closed and witnesses were not properly disclosed under Rule 213 — exclusion was warranted to prevent unfair surprise/prejudice.
- On relocation, the court applied statutory/fact‑specific relocation factors, credited the GAL and forensic testimony that relocation to India would substantially harm the children and noted lack of documentary proof that mother’s employment or immigration status required immediate return. The son’s U.S. citizenship and risk of diminished parental rights in India were weighed. The trial court’s determination that relocation was not in the children’s best interest was not an abuse of discretion.
- On maintenance/division, the court found both parties presently capable of self‑support, no bad faith, and declined to award maintenance, ordering each to bear half GAL fees.

5) Practice implications for family attorneys
- Strict compliance with discovery rules is critical: 215 (expert/psych reports) and 213 (witness disclosure). Late production or untimely subpoenas risk exclusion.
- Pro se litigants are particularly vulnerable — courts expect procedural compliance. Seek extensions or rule‑based relief before deadlines.
- For relocation cases, documentary evidence (employment letters, immigration determinations) and credible expert/GAL testimony are pivotal; appellate courts defer to trial‑court credibility findings.
- Preserve the record: obtain transcripts (bystander reports are imperfect) to support appellate issues.