In re Marriage of Singleton, 2025 IL App (1st) 231100‑U

1. Case citation and parties
- In re Marriage of Victoria Singleton and Michael Singleton, No. 1‑23‑1100 (Ill. App. Ct., 1st Dist., Mar. 31, 2025).
- Rule 23 non‑precedential disposition.

2. Key legal issues
- Proper valuation date for a spouse’s deferred compensation plan and whether inconsistent valuation dates were used.
- Whether the trial court properly characterized and divided marital vs. non‑marital portions of the deferred compensation plan.
- Allocation of child expenses, reservation of child support, and calculation of income for support.
- Appellate review limits where the trial transcript/report of proceedings is absent.

3. Holding/outcome
- Majority of the trial court’s Judgment affirmed.
- Court affirms use of respondent’s retirement date (Aug. 15, 2020) as valuation date for the Plan.
- Reversed and remanded limitedly: the trial court found a 12‑year non‑marital portion of the Plan in its findings but failed to reflect that assignment in the distribution paragraph of the Judgment. Remand to amend the Judgment to (1) assign the 12‑year non‑marital portion to Michael and (2) effectuate a disproportionate division of the marital portion in favor of Victoria (as the court found). Delete erroneous reference that the $68,490.36 debt be paid from “Michael’s 50% marital portion.”
- Child support reserved; court ordered allocation of past school/medical costs and split tuition payments per its income findings.

4. Significant legal reasoning
- Appellate review limited by lack of report of proceedings: under Foutch, absent a transcript, factual findings are presumed supported and any doubt resolved against appellant. That deficiency curtailed review of many claims.
- Valuation date: Budorick’s prohibition on inconsistent valuation dates applies where courts use different valuation dates as a sanction; here no inconsistent date was applied to other assets, so valuation at retirement was within discretion.
- Substance over form: though the court’s findings recognized a non‑marital component, the final decretal language failed to assign it to Michael — remand required to reconcile judgment text with factual findings and to order an appropriate QDRO.

5. Practice implications (for family law practitioners)
- Preserve the record: secure a report of proceedings/bystander’s report; failure limits appellate review.
- Judgment clarity: ensure decretal paragraphs mirror factual findings (especially non‑marital vs. marital allocations) to avoid remand.
- Valuation issues: trial courts have discretion on valuation dates but must avoid inconsistent dates or using dates as de facto sanctions.
- Postjudgment relief: seek clarification or amendment promptly to correct internal inconsistencies (e.g., QDRO language, allocation of specific plan years).
- When dividing retirement/deferred comp, obtain precise valuations, account histories, and draft QDRO language to implement the court’s intent.