In re Marriage of Sanfilippo
Court: Illinois Appellate Court | Published: 10/21/2025
Marriage
Quick Summary:
<h3>Case</h3>
<strong>Citation:</strong> 2025 IL App (1st) 241794‑U (Sept. 29, 2025) (Rule 23 order)
<strong>Court:</strong> Illinois Appellate Court, First Judicial District; <strong>Lower court:</...
Full Case Summary
Case
Citation: 2025 IL App (1st) 241794‑U (Sept. 29, 2025) (Rule 23 order) Court: Illinois Appellate Court, First Judicial District; Lower court: Cook County Circuit Court, No. 15 D 330498 (Judge Matthew Link). Panel: Opinion by Justice Howse; Presiding Justice Fitzgerald Smith and Justice Cobbs concurring.Parties
Petitioner: Linda Sanfilippo. Respondent: David Sanfilippo.Procedural posture
Petitioner filed for dissolution in May 2015. After extensive negotiations the parties executed a written agreed order on May 24, 2022 memorializing an MSA; a prove‑up occurred April 25, 2023 and the trial court entered a dissolution judgment incorporating the MSA on May 10, 2023. Respondent later moved to reconsider/vacate and attack the MSA on grounds of incompetence, coercion, unconscionability, failure to make statutory findings, and denial of a hearing record. The trial court granted a directed finding for petitioner, denied relief (Aug. 16, 2024), and this appeal followed.Material terms of MSA
- Wife: $250,000 (gross) in lieu of maintenance; receives 2330 Sandy Creek, Algonquin, IL free and clear. - Husband: waives maintenance; pays $15,000 (gross) toward wife's attorney fees. - Additional exchange: $35,000 paid to wife for certain vehicles and cash value of two life‑insurance policies.Issues on appeal
Whether the trial court erred in (1) incorporating/enforcing the MSA despite respondent’s claim of mental/physical incapacity and withdrawal of consent; (2) failing to make alleged statutory valuation findings; (3) entering the MSA as unconscionable or procured by coercion; (4) denying a record (court‑reporter) and thereby depriving due process; and (5) applying judicial estoppel and a directed finding.Trial‑court findings and reasoning
- The court found the May 24, 2022 agreed order recorded the parties’ settlement and could be set aside only for fraud, coercion, incompetence, gross disparity, or newly discovered evidence; petitioner did not meet that burden. - At the April 25, 2023 prove‑up respondent repeatedly answered “Yes” that he understood and intended to be bound; a signed Certification and Stipulation confirmed voluntary settlement after full disclosure. - The court found respondent’s testimony and evidence of incapacity not credible, credited Dr. Jaffe’s limited opinion, and concluded respondent failed to prove lack of capacity by the manifest weight of the evidence. - The court determined the MSA was fair, reasonable, not unconscionable, and not the product of coercion. - The court rejected the contention that the statute required independent valuation of every asset before approving an MSA. - The court invoked judicial estoppel because respondent had previously filed a Motion to Enforce the May 24, 2022 order and did not contest prerequisites for estoppel. - The court ruled respondent forfeited challenges based on lack of transcript/bystander’s report and most appellate arguments were insufficiently briefed.Appellate holdings
- Affirmed. The appellate court found no abuse of discretion or manifest‑weight error in the trial court’s factual findings (competence, voluntariness, credibility). - The MSA was not unconscionable or procured by coercion; respondent failed to prove substantive unconscionability and did not meet the clear‑and‑convincing standard for coercion. - The trial court did not err in treating the May 24, 2022 agreed order and the April 25, 2023 prove‑up as binding and in denying postjudgment relief. - Judicial estoppel was properly applied and any challenge to that doctrine was forfeited. - Arguments based on omitted statutory valuation findings, denial of a court reporter, and the bystander’s report were forfeited or without merit; the statute does not automatically void an MSA for lack of independent valuations. - The directed finding in petitioner’s favor stands; respondent did not adequately preserve or brief challenges to that ruling.Reasoning highlights
- Factual determinations about capacity and credibility are reviewed for manifest‑weight error; the appellate court deferred to the trial court’s assessments. - Contract formation principles (offer, acceptance, meeting of minds) and Section 502 (750 ILCS 5/502) support enforcement of MSAs unless unconscionable, procured by fraud/coercion, or contrary to law/public policy. - Precedent (Maher, Filko, Crawford, Gibson‑Terry, Labuz) distinguishes when a court must probe objections; here the record—extensive negotiations, on‑the‑record questioning, and stipulations—made further inquiry unnecessary.Disposition
The appellate court affirmed the Cook County circuit court’s dissolution judgment incorporating the MSA and affirmed denial of respondent’s motions to vacate/reconsider.Ask AI About This Case
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