In re Marriage of Watson, 2019 IL App (2d) 180771-U

- Case citation and parties
In re Marriage of Watson, No. 2-18-0771, 2019 IL App (2d) 180771‑U (Ill. App. Ct. Nov. 22, 2019) (Rule 23 order; non‑precedential). Petitioner‑Appellant: Richard Watson. Respondent‑Appellee: Stephanie (Cox) Watson.

- Key legal issues
1) Whether the trial court abused its discretion in extending and increasing post‑dissolution maintenance.
2) Whether the court’s factual finding that the ex‑wife was unable to work due to mental illness was against the manifest weight of the evidence.
3) Evidentiary rulings (admission of medical letter and other exhibits).
4) Appellate forfeiture for failure to brief issues with authority.

- Holding / outcome
The appellate court affirmed. The trial court did not abuse its discretion in extending and increasing maintenance to $6,250/month for two years; the court’s finding that Stephanie was unable to work due to mental illness was not against the manifest weight of the evidence.

- Significant legal reasoning
- Standard: factual findings on maintenance reviewed for manifest weight; discretionary maintenance determinations under 750 ILCS 5/504 and 510(a‑5) are reversed only if arbitrary or unsupported.
- The trial court considered the statutory factors (504(a) and 510(a‑5)) and found credible evidence (testimony re: PTSD, major depression, daily anxiety, suicide attempts, psychotropic meds, treating psychiatrist’s letter, and inability to obtain disability) supporting unemployability.
- The court distinguished Cantrell and McGory: those cases involved maintenance orders that expressly imposed a duty to seek employment (or school) — the 2014 order here contained no such express obligation.
- Appellant forfeited most appellate arguments by failing to cite legal authority or develop coherent argumentation per Ill. S. Ct. R. 341(h)(7); the court therefore addressed only two properly briefed issues.
- Trial court admitted certain exhibits (including a May 3, 2017 psychiatrist letter and an earlier petition for an order of protection) over objection; the appellate court did not find reversible error.

- Practice implications (concise)
- Initial maintenance orders should expressly state findings and any affirmative obligations (e.g., job‑seeking, schooling) to avoid ambiguity on review.
- When seeking extension/increase, present current, competent medical evidence and vocational expert opinion if asserting disability/unemployability; document applications for SSDI/VA benefits.
- Maintain thorough proof of good‑faith job searches if arguing inability to be self‑supporting is disputed.
- Preserve appellate issues by citing authority and developing legal arguments per Rule 341 — failure likely forfeits review.
- Remember Rule 23 status: this decision is non‑precedential and limited in citation.