In re Marriage of Steidl, 2025 IL App (1st) 241111-U

- Case citation and parties
In re Marriage of Steidl, No. 1-24-1111, 2025 IL App (1st) 241111-U (May 16, 2025) (Rule 23 order). Petitioner-Appellee: Stephan Steidl. Respondent-Appellant (pro se): Ann Le. Appeal from Cook County Circuit Court (No. 20 D 7672).

- Key legal issues
1. May a circuit court, after a contested trial and in the absence of a signed marital settlement agreement (MSA), enter a dissolution judgment containing provisions similar to a proposed MSA?
2. Whether the circuit court abused its discretion in denying respondent’s amended motion to reconsider the dissolution judgment.
3. Effect of an incomplete record (no report of proceedings) on appellate review.

- Holding/outcome
The First District affirmed the circuit court’s denial (with prejudice) of respondent’s amended motion to reconsider. Because no report of proceedings was included, the court presumed the trial court’s factual findings and legal conclusions were proper and supported by the evidence. The appellant failed to show an abuse of discretion.

- Significant legal reasoning
The panel emphasized two controlling points: (1) a trial court is not restricted to adopting or incorporating an unsigned party’s proposed MSA and may enter an independent judgment after hearing evidence; the court had previously informed the parties it could not force agreement to petitioner’s draft MSA; (2) under Illinois appellate practice, when the record lacks a transcript or bystander’s report of the trial, the appellate court must presume the trial court’s rulings were proper and supported by the evidence. Because appellant did not provide the transcript or otherwise establish procedural error or an abuse of discretion, her challenges to numerous judgment provisions (tax indemnity, non‑modifiability, choice of law, mutual releases, waiver of estate claims, conveyance/execution clauses, fee-shifting/enforcement clauses, and retention of jurisdiction) failed. The panel therefore affirmed.

- Practice implications for family law attorneys
- Preserve and produce the record: ensure transcripts or bystander’s reports are in the record — without them, appellate relief is highly unlikely.
- Preserve objections and elicit specific findings at trial if a party intends to challenge inclusion of contract-like provisions in a judgment.
- When drafting/negotiating MSAs, obtain signatures and stipulate to incorporation on the record if that is desired; otherwise the court may craft its own terms after trial.
- Use clear findings and make legal arguments on the record about unconscionability or procedural unfairness; generalized post‑trial motions to reconsider are unlikely to succeed absent articulated abuse of discretion.
- Remember Rule 23 status: this opinion is non‑precedential except as allowed by the rule.