In re Marriage of Xinos

Respondent appealed from a trial court judgment for dissolution of marriage, in which the trial court found that all of respondent’s financial accounts were marital property. On appeal, respondent argued that the trial court erred in granting a motion in limine that barred respondent from presenting evidence that his financial accounts were non-marital property as a sanction for failure to disclose them as non-martial property in discovery and in classifying those accounts as marital property. The appellate court affirmed, finding that respondent forfeited issues related to his allegedly non-marital financial accounts and that even if he had not forfeited the issue, the appellate court would have affirmed the trial court’s ruling on the motion in limine. (HOWSE and ELLIS, concurring)