Respondent appealed from the judgment of the circuit court for dissolution of marriage in which the court found that all of respondent’s financial accounts were marital property. On appeal, respondent argued that the trial court erred when it barred him from presenting evidence that his financial accounts were non-marital property as a sanction for failing to disclose them as non-marital property in discovery and that the trial court erred in classifying those accounts as marital property. The appellate court affirmed, finding that respondent forfeited issues related to his allegedly non-marital financial accounts by failing to make an offer of proof in the trial court and that, even if there was no forfeiture, the trial court did not abuse its discretion in granting the petitioner’s motion in limine regarding evidence that the financial accounts were non-martial property. (HOWSE and ELLIS, concurring)
Illinois Appellate Court
Civil Court
Discovery Sanctions