Illinois Appellate Court
Civil Court
Marriage and Dissolution of Marriage Act
Parties, an opposite-sex couple who had the option to marry at any point during the 13 years that preceded their wedding, cannot add common law claims to their cross-petitions for dissolution based on their pre-marital relationship, based on Illinois public policy which includes legislature's ban on common law marriage. Cross-petitions for dissolution were filed less than 7 months after parties married. Court properly denied wife's motion for leave to add common law claims, and properly refused wife's offer of proof as to those claims. (GORDON and REYES, concurring.)