In re Marriage of Bean-Oyler, 2025 IL App (4th) 250319-U
Guideline Maintenance Calculation Required Before Deviation
Trial courts must calculate and state guideline maintenance amounts before deviating from statutory guidelines. The Fourth District reversed for failure to establish this baseline calculation. Courts cannot use property division or debt allocation to offset maintenance without first determining the guideline amount practitioners must preserve.
Facts
Heather Bean-Oyler appealed a divorce judgment where the trial court awarded the marital home to husband Zachary Oyler and allocated most marital debt to him, apparently in lieu of awarding maintenance to wife. The Fourth District appellate court reviewed whether proper procedures were followed in deviating from maintenance guidelines.
Issue
Whether the trial court complied with the statutory requirement to calculate and state the guideline maintenance amount before deviating from the guidelines.
Holding
The trial court erred by failing to calculate and state the guideline maintenance amount before deviation. The case was reversed and remanded for proper calculation of statutory guidelines and reevaluation of maintenance and property division based on that baseline figure.
Key Reasoning
- Statutory mandate requires trial courts to determine and state guideline maintenance amounts before imposing any deviation
- Procedural requirement is necessary to permit meaningful appellate review of whether deviation is justified
- Extensive factual findings cannot cure the omission of the baseline guideline calculation
- Property division and debt allocation cannot offset maintenance without established guideline baseline
Practical Impact
For Petitioners
Always request court to calculate and state guideline maintenance on record before seeking any deviation or offset through property division
For Respondents
Challenge any maintenance deviation where court failed to first establish statutory guideline baseline calculation
When This Applies
Applies when courts deviate from maintenance guidelines; does not affect cases where guidelines are followed without modification
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