In re Marriage of Beaton, 2022 IL App (2d) 200556-U

- Case citation and parties
In re Marriage of Beaton, 2022 IL App (2d) 200556-U (Ill. App. Ct. Nov. 4, 2022) (Rule 23 order). Petitioner-Appellee: Renee Beaton. Respondent-Appellant: Jay Beaton.

- Key legal issues
1) Whether the trial court properly treated recurring family transfers and proceeds from a family land sale as income for purposes of calculating maintenance and child support.
2) Whether the trial court abused its discretion in finding respondent in indirect civil contempt for willful failure to pay court-ordered maintenance/child support.
3) Whether the appellate court had jurisdiction to review the underlying dissolution judgment.

- Holding/outcome
The appellate court dismissed the portions of the consolidated appeals challenging the judgment of dissolution for lack of jurisdiction. It affirmed the trial court’s contempt finding, concluding the trial court did not abuse its discretion in finding respondent in indirect civil contempt for willfully failing to make support payments.

- Significant legal reasoning (concise)
The trial court found persuasive, largely uncontested evidence that respondent received significant, regular financial assistance from family: monthly wire transfers from his mother (variously characterized at trial as ~$3,000–$5,000), an $85,000 transfer from a brother (treated as a gift because there was no promissory note or repayment), and $370,000 in farm-sale proceeds which respondent could not adequately account for. The court concluded consistent family gifts and unaccounted windfall expenditures can be included in income for support calculations. The court used a practical method (examining the 20 months from receipt of the farm proceeds to trial and dividing the unaccounted funds) to assess ongoing monthly resources, deemed $5,000/month conservative, and ultimately imputed an additional $3,500/month to respondent’s income for support purposes. The appellate court deferred to the trial court’s factual findings and discretion and affirmed the contempt adjudication for willful nonpayment.

- Practice implications
- Regular, voluntary family transfers and unexplained depletion of a windfall can be treated as income for maintenance/child support; courts will scrutinize lack of documentation and may impute income.
- Transfers characterized as “loans” must be evidenced and repaid to avoid reclassification as gifts; contemporaneous documentation (notes, repayment records) is critical.
- Parties should preserve bank records and explanations for large receipts/disbursements; failure to account for funds can materially increase child support/maintenance obligations.
- Enforcement via indirect civil contempt remains available and will be upheld absent an abuse of discretion.
- Note: this is a Rule 23 (nonprecedential) decision; treat as persuasive but not binding precedent.