In re Marriage of Mitchell, 2025 IL App (1st) 240562-U

Facts

Rhet Mitchell and Burnetta Herron divorced after marriage from 2010-2019 with prenuptial agreement allowing reimbursement for household expenses. Trial court excluded Herron's reimbursement evidence before January 1, 2015. Herron appealed the evidentiary ruling and judgment.

Issue

Whether the trial court properly excluded evidence of reimbursement claims for household expenses incurred before January 1, 2015 under the parties' prenuptial agreement.

Holding

The appellate court vacated the exclusion order and remanded, finding the temporal cutoff improper. Expert report limitations typically affect weight rather than admissibility absent demonstrable unreliability. The blanket exclusion impermissibly curtailed respondent's ability to prove her prenuptial agreement claim.

Key Reasoning

• Prenuptial agreements expressly preserving reimbursement rights must be enforced according to their terms
• Expert evidence foundational concerns generally go to weight and cross-examination, not wholesale exclusion
• Time-based exclusions of central evidence require firm foundational proof of unreliability
• Complete appellate records are necessary to challenge evidentiary rulings effectively