In re Marriage of Aleman-Mistar

2026 IL App (1st) 240596-U
CourtAppellate Court of Illinois
DecidedMarch 24, 2026
Docket1-24-0596
StatusUnpublished

This text of 2026 IL App (1st) 240596-U (In re Marriage of Aleman-Mistar) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Marriage of Aleman-Mistar, 2026 IL App (1st) 240596-U (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 240596-U

FIRST DISTRICT SECOND DIVISION March 24, 2026

No. 1-24-0596

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). __________________________________________________________________________

IN RE THE MARRIAGE OF: ) ) THERESA ALEMAN-MISTAR, ) ) Appeal from the Circuit Court Petitioner-Appellee, ) of Cook County, Illinois ) vs. ) No. 2020 D 8130 ) ELHASSAN MISTAR, ) Honorable H. Yvonne Coleman ) Judge Presiding Respondent-Appellant. ) __________________________________________________________________________

JUSTICE ELLIS delivered the judgment of the court. Presiding Justice Van Tine and Justice McBride concurred in the judgment.

ORDER

¶1 Held: Affirmed. Husband did not establish on appeal that court erred in valuation of husband’s income or of marital assets.

¶2 This appeal concerns a judgment of dissolution of marriage between petitioner Theresa

Aleman Mistar and her husband, respondent Elhassan Mistar. Elhassan appeals, citing two errors

in the circuit court’s judgment: its valuation of his income and its valuation of marital assets.

¶3 These valuations were made after a trial for which we lack a transcript, a stipulation, or a

bystander’s report. And Elhassan’s brief does not remotely touch on the underlying facts of this

case or the evidence presented. Principally for these reasons, we cannot say the circuit court

abused its discretion in its valuations and thus affirm. No. 1-24-0596

¶4 We begin with the deficiencies hampering our review. For one, Elhassan’s statement of

facts is all of three sentences. He tells us only that (1) Theresa filed for dissolution of marriage;

(2) the court entered a judgment of dissolution; and (3) Elhassan filed a notice of appeal.

¶5 Illinois Supreme Court Rule 341(h) (eff. July 1, 2008) governs the contents of an

appellant’s brief. The rules are “not mere suggestions.” Hall v. Naper Gold Hospitality LLC,

2012 IL App (2d) 111151, ¶ 7. Rule 341(h)(6) requires a statement of facts that contains the facts

“necessary to an understanding of the case.” Ill. S. Ct. R. 341(h)(6) (eff. July 1, 2008). We may

strike a statement of facts that fails to substantially comply with this rule. Hall, 2012 IL App (2d)

111151, ¶ 9. We will choose not to strike Elhassan’s brief and proceed as best we can.

¶6 The statement of facts aside, Elhassan’s argument section cites only one document, the

court’s written judgment—not one citation to documentary evidence supporting his position. The

appellant must provide those record citations; “ ‘it is not our duty to search the record for

material upon which to base a reversal.’ ” Vance v. Joyner, 2019 IL App (4th) 190136, ¶ 80

(quoting Farwell Construction Co. v. Ticktin, 84 Ill. App. 3d 791, 802 (1980)).

¶7 Finally, we have no transcript of the proceedings or any substitute by way of stipulation

or bystander’s report. The burden is on the appellant to provide a complete record on appeal.

Foutch v. O'Bryant, 99 Ill. 2d 389, 391-92 (1984). Any doubt arising from the incompleteness

will be resolved against the appellant. Id. at 392. Said differently, “[w]hen the record on appeal is

incomplete, a reviewing court may indulge in every reasonable presumption favorable to the

judgment from which the appeal is taken, including that the trial court ruled or acted correctly.”

Fraser v. Jackson, 2014 IL App (2d) 130283, ¶ 22 (internal quotation marks omitted).

¶8 That absence of a transcript is particularly troublesome here, as Elhassan correctly notes

that the court’s valuation of assets in a marital-dissolution action is reviewed for an abuse of

2 No. 1-24-0596

discretion. In re Marriage of Schneider, 214 Ill. 2d 152, 162 (2005). It is nearly impossible for us

to determine whether the court abused its discretion when we cannot read a transcript of the

testimony. Foutch, 99 Ill. 2d at 392.

¶9 Indeed, in the absence of a transcript of an evidentiary hearing, “Foutch dictates that we

would simply presume the trial court’s order was in conformity with the law and had a sufficient

factual basis.” Evans v. Cook County State’s Attorney, 2021 IL 125513, ¶ 38; see Illinois

Founders Insurance Co. v. Williams, 2015 IL App (1st) 122481, ¶ 56 (absence of report of

proceedings or acceptable substitute frustrated appellate review for abuse of discretion); In re

Marriage of Salvetiu, 2023 IL App (1st) 211162-U, ¶ 33 (appellate court could not find abuse of

discretion in court’s maintenance award without transcript of evidentiary hearing).

¶ 10 The one-two combo of providing no substantive factual background and the lack of a

transcript makes our review exceptionally difficult. If we are directed to no evidence

undermining the trial court’s written findings, we are hard-pressed to find error in those findings.

¶ 11 With that steep hill to climb, Elhassan first argues that the court erred in its calculation of

his income for the purpose of determining his maintenance obligation to Theresa. He says the

court erred in imputing a gross annual income of $100,000 to him, because the court may impute

income only if income is uncertain—and in this case, he says, “the income is certain.”

¶ 12 A court may impute income to a spouse if the spouse (1) becomes voluntarily

unemployed; (2) tries to evade a support obligation; or (3) unreasonably fails to take advantage

of a business opportunity. In re Marriage of Van Hoveln, 2018 IL App (4th) 180112, ¶ 40; In re

Marriage of Blume, 2016 IL App (3d) 140276, ¶ 30. The decision itself to impute income is

reviewed for an abuse of discretion. In re Marriage of Britton, 2022 IL App (5th) 210065, ¶ 57.

¶ 13 Though Elhassan characterizes the evidence of his income as “certain,” the circuit court

3 No. 1-24-0596

clearly did not. In two different ways, the court found that Elhassan was trying to evade his

support obligations. For one, he had stopped paying his temporary maintenance obligation

without court authorization and had been found in contempt.

¶ 14 For another, the court did not find Elhassan credible in fully disclosing the income of his

business. The court noted that “Elhassan does not maintain records of his business revenue other

than his bank deposits. He did not provide evidence of contracts, agreements, business receipts,

or any other proof of his business transactions.” The court found that “a significant amount of his

business income is derived from cash transactions and payments,” and “Elhassan did not present

credible or sufficient evidence to prove that he included all of his cash receipts in the bank

records during the past five years.” The court also raised questions “regarding the reasonableness

of some of his business expenses and liabilities.”

¶ 15 The court clearly took issue with the evidence Elhassan presented and believed he was

significantly understating his income to avoid his maintenance obligation. We have no basis to

find an abuse of discretion in that finding. See In re D.O., 2025 IL App (3d) 240645-U, ¶ 14 (in

imputing net income, trial court correctly considered respondent’s “credibility and forthrightness

in disclosing his income.”); In re Marriage of Sweet, 316 Ill. App. 3d 101, 109 (2000) (same).

¶ 16 Elhassan points to the court’s written order, where the court noted that Elhassan claimed

that he is “unable to earn more than $50,000—a high of $55,000—per year from his business,” a

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2026 IL App (1st) 240596-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-marriage-of-aleman-mistar-illappct-2026.