In re Marriage of Slater

2019 IL App (1st) 181947-U
CourtAppellate Court of Illinois
DecidedNovember 18, 2019
Docket1-18-1947
StatusUnpublished

This text of 2019 IL App (1st) 181947-U (In re Marriage of Slater) 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 Slater, 2019 IL App (1st) 181947-U (Ill. Ct. App. 2019).

Opinion

2019 IL App (1st) 181947 Nos. 1-18-1947 & 1-19-0178 (cons.) Order filed November 18, 2019 First Division

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS

FIRST DISTRICT

) Appeal from the Circuit Court In re MARRIAGE OF SLATER, ) of Cook County. ) (JOHN SLATER, ) ) No. 17 D 2157 Petitioner-Appellant, ) ) and ) ) The Honorable KATHLEEN SLATER, ) David Haracz, ) Judge, presiding. Respondent-Appellee). )

JUSTICE HYMAN delivered the judgment of the court. Presiding Justice Griffin and Justice Pierce concurred in the judgment.

ORDER

¶1 Held: Issue regarding the determinative dates of the premarital agreement for classifying property as marital or non-marital was forfeited when party did not appeal the trial court’s declaratory judgment ruling after the trial court added Illinois Supreme Court 304(a) language. The trial court properly allocated the parties’ multiple bank accounts as marital/non-marital; ordered reimbursement of the marital estate for various monies used by one party in violation of the terms of the premarital agreement; and ordered an income tax refund shared in equal parts as the parties had agreed. Nos. 1-18-1947 & 1-19-0178 (cons.)

¶2 Kathleen and John Slater married one week after signing a prenuptial agreement.

Eighteen months later, Kathleen filed for divorce. Four months later, she dismissed her petition.

Eight days after that, John filed a petition for dissolution.

¶3 John moved for partial summary judgment, arguing that under the prenuptial agreement

the determinative dates for defining marital property should be the date the parties married and

the date Kathleen filed for divorce. John also asked the court to consider other issues.

¶4 In response, Kathleen moved for declaratory judgment to set the time frame for defining

marital property. She argued that under the prenup the relevant time period should end on the

date John filed his petition for dissolution, the filing that ultimately lead to the parties’ divorce.

The trial court ruled on the declaratory judgment in Kathleen’s favor, finding the date John filed

for dissolution the relevant end date. The trial court denied John’s motion for partial summary

judgment.

¶5 After a bench trial, the trial court entered judgment for dissolution of marriage. John filed

a motion for reconsideration, which the trial court denied. John appeals from both orders.

¶6 We affirm. John forfeited his argument regarding the effective end date for enforcing the

prenup by not appealing the declaratory judgment ruling after obtaining Supreme Court Rule

304(a) language. On the other issues John has raises on appeal, the trial court properly ruled.

¶7 Background

¶8 Premarital Agreement

¶9 John and Kathleen signed a “Premarital Agreement” that took effect on the date of the

marriage, May 2, 2015. Paragraph 3, entitled “Non-marital Property and Transmutation,”

provided “the following items shall be deemed Non-Marital Property, whether acquired by the

applicable party before or during marriage,” unless a written and signed memorandum

-2- Nos. 1-18-1947 & 1-19-0178 (cons.)

demonstrates an intent to gift his or her property and “transmute it to marital property.”

Paragraph 3(E) included as non-marital property “[a]ll earnings, income, and other benefits

derived from property designated as such party’s schedule of property interests attached to this

Agreement.” Attached were Schedule A listing John’s non-marital assets and liabilities and

Schedule B listing Kathleen’s.

¶ 10 Paragraph 3(G) included as non-marital property either owned with “one or more other

persons, none of whom is the other party,” and paragraph 3(J) included “[i]ncome, including but

not limited to salary, severance salary, dividends, distributions, deferred income, options (vested

and non-vested), grants (vested and non-vested) and retirement benefits received by either party

from any source resulting from that party’s personal efforts or otherwise during the marriage,

unless added to a joint account as described in paragraph 5 of this Agreement.” (Emphasis in

original.)

¶ 11 In paragraph 3(K), the parties agreed that each could seek reimbursement to marital funds

for the value of “marital funds or assets used to purchase, improve, maintain or otherwise

contribute to the value of a party’s non-marital property without the express written consent of

the other party.” Additionally, the parties agreed that each would be reimbursed for the full

amount of $10,000 or more of his or her Non-Marital Property used for a down payment or

improvement to any co-owned real property, “unless otherwise agreed by the parties in writing

prior to the proceeds from the sale of such property being divided.” A contribution less than

$10,000 would not be reimbursed unless the parties agreed otherwise in writing.

¶ 12 Paragraph 5 covered “Joint Household and Future Joint or Marital Property.” Paragraph

5(E)(1) provided: “Bank Accounts – Separate accounts held at the date of marriage shall remain

separate property. The parties intend to establish joint accounts which shall become marital

-3- Nos. 1-18-1947 & 1-19-0178 (cons.)

property.” Paragraph 5(E)(2) read: “Investment accounts – Separate accounts held at the date of

the marriage shall remain separate property. The parties intend to establish joint accounts which

shall become marital property.” Section 5(E)(3) concerned earnings an employer actually paid

“during the marriage and before either party files for divorce.” This section also included

language pertaining to stock John received as part of his executive compensation. Paragraph

5(E)(4) regarding “Retirement Accounts” added the term “Non-Marital”—“Separate accounts

held at the date of the marriage shall remain separate Non-Marital Property.”

¶ 13 The four subsections of paragraph 5(E) included the qualifier “if the marriage is

dissolved,” in which case John and Kathleen would each own one-half.

¶ 14 Litigation

¶ 15 On November 28, 2016, Kathleen petitioned for dissolution of marriage. She withdrew

her petition on March 1, 2017. John filed his petition for dissolution eight days later.

¶ 16 John moved for partial summary judgment, contending the time to determine joint

property should begin on the date of the marriage and end on the date Kathleen filed for

dissolution. He argued the prenup did not specify a petition for dissolution had to result in

divorce and had the parties intended that a petition had to lead to a final judgment of separation

or divorce, they could have included appropriate language. Kathleen petitioned the court for a

declaratory judgment, contending that the dates should instead be the date of the marriage until

John filed in March 2017.

¶ 17 The trial court denied John’s motion for partial summary judgment and granted

Kathleen’s declaratory judgment motion, stating, “I don’t think it’s sensible that it could be a

filing that doesn’t lead to a dissolution.” The written order entered November 22, 2017, said,

-4- Nos. 1-18-1947 & 1-19-0178 (cons.)

“the court declares that the relevant date for determination or marital/non-marital property is

March 9, 2017 if the filing results in a dissolution of marriage.”

¶ 18 John asked the court to add Illinois Supreme Court Rule 304(a) language stating the order

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2019 IL App (1st) 181947-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-marriage-of-slater-illappct-2019.