In re Marriage of Greer, 2019 IL App (1st) 162885-U

- Case citation and parties
In re Marriage of Greer, No. 1-16-2885, 2019 IL App (1st) 162885‑U (Apr. 25, 2019) (Ill. App. Ct., 1st Dist., Rule 23 order). Petitioner-Appellee: Maurissa Greer. Respondent-Appellant: Anthony Walker.

- Key legal issues
1) Whether the trial court was required to make the specific findings mandated by amended 750 ILCS 5/504 when awarding maintenance.
2) Whether the trial court abused its discretion in setting maintenance at $600/month for 24 months.

- Holding/outcome
Affirmed. The appellate court upheld the trial court’s maintenance award of $600 per month for 24 months.

- Significant legal reasoning (concise)
- Applicable law: The court determined the version of the Marriage and Dissolution of Marriage Act that became effective January 1, 2016 (which added the subsection requiring “specific findings of fact” for maintenance awards—see 750 ILCS 5/504(b‑2)) applied because the dissolution judgment was entered after that effective date and section 801(b) makes the new Act govern pending actions where no judgment had been entered.
- Record inadequacy: The core reason for affirmance was procedural — the appellant failed to provide an adequate record for review. There was no court‑reporter transcript or bystander’s report of the dissolution hearing, so the appellate court could not evaluate whether the trial court made the statutorily required findings or abused its discretion. The appellant bears the burden to present a sufficient record to demonstrate error; absent a transcript or agreed statement of facts, appellate review is necessarily limited and reversible error cannot be presumed. The opinion cites precedent that where the basis for maintenance is established in the record explicit findings may not be mandatory, but under the amended statute the requirement exists — nonetheless appellant’s failure to preserve the record was dispositive.

- Practice implications (bullet points)
- Always preserve a complete record when litigating maintenance: secure a court reporter for hearings, or prepare an agreed statement of facts if no reporter is available.
- After the 2016 amendments to §504, request specific written findings of fact (or make a posttrial motion) when maintenance is contested to satisfy the statutory requirement and to preserve issues for appeal.
- Ensure detailed financial disclosures and exhibits are admitted and appear in the record; without them an appellant cannot demonstrate abuse of discretion.
- Note: this is a Rule 23 (non‑precedential) order; persuasive but not binding precedent.