In re Marriage of Keegan, 2022 IL App (2d) 190495

1. Case citation and parties
- In re Marriage of Keegan, 2022 IL App (2d) 190495.
- Petitioner-Appellant: Colleen A. Keegan. Respondent-Appellee: Jon C. Papin.

2. Key legal issues
- Whether the trial court abused its discretion in granting respondent’s discovery‑sanction motions that barred petitioner from introducing medical records and testifying as her own medical expert after she failed to produce records, submit to a Rule 215 exam, and sit for depositions.
- Whether the court abused its discretion by directing petitioner not to confer with counsel about her testimony during trial recesses.
- Whether the denial of maintenance to petitioner was against the manifest weight of the evidence.

3. Holding/outcome
- The Appellate Court (2d Dist.) affirmed the trial court. The court’s discovery sanctions (barring medical evidence/expert testimony), its restriction on recess communications, and its denial of maintenance were upheld.

4. Significant legal reasoning (concise)
- Physical condition was “in controversy” because petitioner asserted medical limitations as a basis for maintenance and reduced earning capacity; therefore the trial court properly ordered a Rule 215 examination and production of medical records.
- Petitioner repeatedly failed to comply with discovery (failure to produce records, failure to execute releases, refusal/delay in attending court‑ordered deposition and Rule 215 exam), despite court orders and warnings. Under Supreme Court Rules (notably Rules 213/215/219), the trial court had discretion to impose sanctions for discovery abuse. The court’s choice to bar medical records and to preclude petitioner from giving expert medical testimony was an appropriate, proportionate sanction given the prejudice to respondent and the prior warnings.
- The restriction on conferring with counsel during recesses was addressed as a trial‑control measure to prevent coaching and preserve trial fairness; the appellate court found no abuse of discretion.
- On maintenance, petitioner’s claim depended heavily on the barred medical proof and on testimony the court found unreliable or unsupported. The trial court’s factual findings as to petitioner’s earning capacity and lack of entitlement to maintenance were not against the manifest weight of the evidence.

5. Practice implications for family law attorneys
- When a party puts physical condition in controversy, promptly comply with Rule 215 exams and produce medical releases/records; failure to do so risks exclusion of evidence and testimony.
- Treat Rule 213 disclosure obligations seriously—late identification of treating physicians or withholding records invites sanctions under Rule 219.
- Preserve a clear record if you object to trial‑control orders (e.g., restraints on recess communications); but expect courts to police potential witness coaching.
- For maintenance claims premised on incapacity, corroborating documentary medical proof is critical; discovery gamesmanship can be dispositive.