Respondent appeals from order granting in part and denying in part amended petition to terminate or reduce maintenance awarded to his ex-wife. Reversing portion of circuit court's judgment declining to address, pursuant to law-of-the-case doctrine, the propriety of duration of wife's maintenance award and concurrently finding that provisions of Section 504(b-1) of Marriage and Dissolution of Marriage Act do not apply to this case. Law-of-the-case doctrine does not apply, as neither party appealed 2011 order awarding wife indefinite maintenance; and as a subsequent court is not precluded from modifying award in event of substantial change in circumstances. Remanded for limited purpose of addressing duration issue pursuant to Section 504(b-1). Remainder of order, including reduction in amount of maintenance award, is affirmed. (HUTCHINSON and SPENCE, concurring.)
Illinois Appellate Court
Civil Court
Maintenance