In re Marriage of Stranyiczki, 2019 IL App (2d) 180220-U

1. Case citation and parties
- In re Marriage of Stranyiczki, 2019 IL App (2d) 180220‑U (Ill. App. Ct., 2d Dist., July 23, 2019) (Rule 23 order — non‑precedential).
- Petitioner/Appellee: Michelle Stranyiczki. Respondent/Appellant: Lorand Stranyiczki.

2. Key legal issues
- Whether the trial court properly applied the law‑of‑the‑case doctrine to bar relitigation of the imputed‑income finding made in prior proceedings.
- Whether the trial court’s finding of indirect civil contempt (failure to pay increased child support after imputation) was against the manifest weight of the evidence — i.e., whether respondent proved inability to pay or lack of willfulness.

3. Holding/outcome
- Affirmed. The appellate court held the trial court properly applied the law‑of‑the‑case doctrine and that the contempt finding was supported by the evidence. The trial court’s purge amount ($11,879.45) was left intact.

4. Significant legal reasoning
- Law‑of‑the‑case: The court explained the doctrine prevents relitigation of issues already decided in the same case to protect settled expectations and ensure consistency. The court rejected appellant’s contention (relying on Scheffel) that the doctrine applies only to questions of law, noting it can apply to previously decided issues of fact as well; Scheffel does not preclude application to factual issues where the same issue remains presented. Application here was appropriate because the prior proceedings established that respondent colluded to shut down his business and the court had previously imputed substantial income.
- Contempt burden shifting: Once petitioner made a prima facie showing of nonpayment (payment records/garnishments documented arrears), the burden shifted to respondent to prove nonwillfulness or inability to pay. The court found respondent’s witnesses unpersuasive, documentary detail lacking, and his claimed attempts to restart business or obtain financing insufficiently proven. The evidence supported a finding that respondent remained effectively able to earn the previously imputed income and willfully disobeyed the support order.

5. Practice implications
- Treat prior trial/appellate findings (especially imputed income) as binding in subsequent enforcement proceedings unless changed circumstances are clearly proved.
- In contempt/support enforcement hearings, litigants should: (a) present clear payment/garnishment records to establish prima facie arrears; (b) defend with contemporaneous, detailed documentary proof of inability to pay (bank statements, loan denials, business records, tax returns); (c) emphasize witness credibility and specificity when claiming changed circumstances.
- Note: Rule 23 status — this opinion is non‑precedential, but useful persuasive authority for similar fact patterns.