In re Marriage of Mathis, 2012 IL 113496

1. Case citation and parties
- In re Marriage of Mathis, 2012 IL 113496 (Ill. Dec. 28, 2012).
- Appellant: Kenneth W. Mathis. Appellee: Terri D. Mathis.

2. Key legal issues
- In a bifurcated dissolution (grounds resolved first; ancillary issues reserved), what date controls valuation of marital property under 750 ILCS 5/503(f): (a) the date the court enters the dissolution judgment (grounds), or (b) the date of the later trial/hearing on ancillary/property issues (or some date near that trial)?

3. Holding/outcome
- The Illinois Supreme Court reversed the appellate court. It held the proper valuation date in a bifurcated proceeding is the date the trial court enters the judgment of dissolution following the trial on grounds (or another date reasonably proximate to that dissolution judgment). The cause was remanded to the circuit court.

4. Significant legal reasoning
- Statutory interpretation: the Court read section 503(f) in the context of the Illinois Marriage and Dissolution of Marriage Act and longstanding Illinois precedent treating the date of dissolution judgment as the valuation cutoff. The Court concluded that the date of dissolution (the entry of the grounds judgment) is the natural, statutory anchor for determining what is marital property and its value.
- Equity and predictability: tying valuation to the dissolution judgment advances the Act’s scheme that distinguishes marital from postdissolution (nonmarital) acquisitions and avoids rewarding strategic delay or postjudgment efforts that would otherwise change marital status of property.
- Limited judicial discretion: the Court recognized there may be circumstances justifying selection of a date near the dissolution judgment (e.g., to fairly reflect values when delay is unavoidable), but such flexibility is narrow — the valuation date should ordinarily be the dissolution judgment date or a date close to it, not the much later ancillary trial date.
- The Supreme Court rejected the appellate court’s reading that “date of trial” in §503(f) refers to the later ancillary trial when property is litigated.

5. Practice implications
- In bifurcated cases, counsel should assume the valuation cutoff will be the date the court enters the dissolution judgment unless the court expressly chooses a proximate alternate date.
- To protect clients: (a) litigate and secure an explicit valuation date in the judgment or by motion soon after grounds are resolved; (b) preserve objections and seek Rule 308 certification if valuation-date disputes arise; (c) prepare valuations tied to the dissolution-judgment date and, if delay occurs, develop evidence and argument supporting a proximate alternate date.
- Expect courts to resist permitting valuation tied to far-later ancillary trials except for narrow, justified circumstances.