In re Marriage of Chapa, 2022 IL App (2d) 210772

1. Case citation and parties
- In re Marriage of Chapa, 2022 IL App (2d) 210772.
- Petitioner-Appellee: Daniel Chapa III. Respondent-Appellant: Nancy Lea Chapa.

2. Key legal issues
- Whether the trial court properly applied the decree’s instruction that any petition to extend reviewable maintenance be decided de novo under 750 ILCS 5/504(a) (rather than requiring a prerequisite showing of changed circumstances or focusing solely on the recipient’s “best efforts” to become self‑supporting).
- Whether the trial court considered statutory factors in ruling on a request for contribution to attorney fees under 750 ILCS 5/503(j).
- Procedural issues relating to temporary maintenance and appellate briefing compliance (Illinois Supreme Court Rule 341).

3. Holding/outcome
- Appellate court vacated the December 9, 2021 order denying Nancy’s petition to extend maintenance and denying fee relief, and remanded for the trial court to reconsider Nancy’s petitions consistent with the opinion (i.e., applying the required statutory standards). Judgment vacated; cause remanded.

4. Significant legal reasoning (concise)
- The dissolution judgment explicitly required that any request to extend maintenance be reviewed de novo pursuant to section 504 of the Illinois Marriage and Dissolution of Marriage Act (750 ILCS 5/504(a)), and specified that no proof of a “substantial change in circumstances” was required. The Appellate Court held the trial court erred by treating Nancy’s “best efforts” obligation as a threshold bar and by failing to apply the section 504(a) factors in its analysis.
- The trial court instead focused on Nancy’s conduct (delays in sale of the marital residence, alleged lack of self‑improvement, credibility concerns, and possible undisclosed support from a boyfriend) and terminated maintenance without the statutorily required factor-by-factor consideration.
- Likewise, the court failed to apply section 503(j) criteria in resolving Nancy’s motion for contribution to attorney fees.
- The Appellate Court also addressed briefing compliance issues (Rule 341) but resolved the merits by remand rather than imposing sanctions.

5. Practice implications for family law practitioners
- Where a dissolution judgment sets a specific standard (e.g., de novo review under §504), trial courts must follow that mandate and address the statutory factors explicitly and on the record; treating contractual/judgment provisions as mere guidance or imposing extraneous prerequisites risks reversal.
- When seeking or opposing maintenance extensions, litigants should brief and offer evidence tied to the §504(a) factors; courts must avoid confining inquiry to a recipient’s “best efforts” alone.
- Requests for attorney‑fee contributions require explicit consideration of §503(j) factors and findings.
- Preserve the record, obtain express findings on statutory factors, and ensure appellate briefs comply strictly with Rule 341 to avoid procedural defenses or sanctions.