In re Marriage of Ratz, 2022 IL App (2d) 200216-U

- Case citation and parties
In re Marriage of Ratz, 2022 IL App (2d) 200216‑U (Ill. App. Ct. 2d Dist. Mar. 23, 2022) (Rule 23 order, non‑precedential). Petitioner/Appellee: Sharon C. Ratz. Respondent/Appellant: Roger W. Ratz.

- Key legal issues
1) Allocation/division of respondent’s Lucent pension (procedural and substantive).
2) Whether respondent dissipated marital assets (gifts/transfers to a third party, undermarket rental, purchase/sale of a BMW).
3) Validity/handling of a $50,000 predistribution to each party from sale proceeds.
4) Trial court’s award of $30,000 in attorney fees to petitioner.
5) Procedural forfeiture based on appellant’s briefing.

- Holding / outcome (short)
The appellate court affirmed. Several appellate contentions were forfeited for inadequate briefing (failure to cite the record or authority). The trial court’s dissipation findings were not against the manifest weight of the evidence. The attorney‑fee award and other rulings were upheld.

- Significant legal reasoning (concise)
- Forfeiture: The court repeatedly emphasized Illinois briefing requirements — factually intensive claims require pinpoint record citations; legal claims require authority. Because appellant failed to provide adequate citations to the record for contested factual matters and failed to cite supporting authority for the predistribution argument, those issues were forfeited.
- Manifest‑weight review of dissipation: The court accepted the trial court’s credibility evaluations and factual findings (evidence of purchase and concealment of a condo titled solely in respondent’s name, below‑market rents to the third party, large transfers/payments to the third party, purchase and later sale of a BMW). Those facts supported the trial court’s conclusion that respondent dissipated marital assets for a nonmarital purpose; appellate reversal was not warranted.
- Attorney fees: The trial court did not abuse its discretion in awarding fees given the parties’ relative financial positions and respondent’s conduct (including the dissipation conduct and failure to comply with disclosure orders).

- Practice implications for family lawyers
- Preserve and document: obtain detailed findings (amounts, dates, beneficiaries, purpose) when alleging dissipation. Link transfers to nonmarital benefit and show timing relative to the petition.
- Briefing discipline: include precise record citations for fact disputes and legal authority for claims; failure risks forfeiture.
- QDRO/pension issues: seek specific trial findings on marital portion and entry of a QDRO; request interim relief (temporary pension payments) if needed.
- Fee motions: frame attorney‑fee requests with financial disparity and misconduct evidence.
- Note Rule 23 status: the opinion is non‑precedential; treat holdings as persuasive but not binding.