2026 IL App (4th) 260173 No. 2026 IL App (4th) 260173
Rule 23 · Civil —Family Law
- ¶1 Fourth District affirms that proof of just one statutory unfitness ground suffices, even if a parent's appeal ignores an unchallenged ground.
- ¶2 Extensive corroborated evidence of an injurious environment causing children's PTSD adequately supported a stipulated unfitness finding.
- ¶3 Useful for family law and child welfare attorneys handling contested stipulations to unfitness and best-interest hearings in termination proceedings.
2026 IL App (5th) 250139 No. 2026 IL App (5th) 250139
Rule 23 · Civil —Family Law
- ¶1 Fifth District affirms 38-year maintenance award, finding husband forfeited every argument by failing to cite supporting legal authority.
- ¶2 Court confirms section 504(b-1)(1)(B) permits maintenance terms equal to marriage length (20+ years) or indefinite duration.
- ¶3 Useful for family law practitioners drafting appellate briefs—illustrates severe consequences of citing authority only for standard of review under Rule 341(h)(7).
2026 IL App (4th) 260345 No. 2026 IL App (4th) 260345
Rule 23 · Civil —Family Law
- ¶1 A trial court may mention evidence outside the statutory nine-month periods without it constituting reversible error, if not relied upon.
- ¶2 DCFS's facilitation of services defeats a parent's claim that noncompliance should be excused due to scheduling or agency inaction.
- ¶3 Useful for family law practitioners handling parental fitness and termination appeals under the Adoption Act's reasonable-progress standard.
2026 IL App (4th) 251109 No. 2026 IL App (4th) 251109
Rule 23 · Civil —Administrative Law
- ¶1 Fourth District affirms no FOIA violation where trial court found requested records simply did not exist.
- ¶2 Appellant's failure to provide reports of proceedings requires appellate court to presume trial court's rulings had a sufficient factual basis.
- ¶3 Useful for appellate practitioners and FOIA litigators handling pro se inmate suits, incomplete records, and appellee-brief-absent scenarios.
2026 IL App (4th) 260340 No. 2026 IL App (4th) 260340
Rule 23 · Civil —Juvenile Law
- ¶1 Appellate court granted counsel's Anders motion to withdraw, finding no meritorious issues in mother's neglect/dispositional appeal.
- ¶2 Neglect finding upheld under clear-and-convincing standard (ICWA applied) based on 14 positive drug tests and domestic violence incident.
- ¶3 Useful for juvenile law and family law practitioners handling neglect adjudications, ICWA-implicated cases, and Anders withdrawal motions in dependency appeals.
2026 IL App (1st) 250345 No. 2026 IL App (1st) 250345
Rule 23 · Civil —Civil Procedure
- ¶1 A motion to reconsider tolls the appeal deadline if it substantively challenges the judgment, regardless of its primary focus or caption.
- ¶2 Post-judgment leave to amend is governed by section 2-616(c)'s conform-to-proofs standard, not the liberal pre-judgment Loyola factors under 2-616(a).
- ¶3 Useful for civil litigators handling class actions, motions to reconsider, and appeals involving denied leave to amend after dismissal with prejudice.
2026 IL App (1st) 250620 No. 2026 IL App (1st) 250620
Opinion · Civil —Real Estate Law
- ¶1 Section 38.1(c)'s five-month bonding-over deadline runs from the first pleading asserting the lien claim, not from any later amended pleading.
- ¶2 Dismissal of a complaint with leave to amend does not end the 'pending action' if the case remains otherwise active, such as when stayed for mediation.
- ¶3 Useful for construction and real estate litigators handling mechanics lien disputes and defendants seeking to substitute a surety bond under the Mechanics Lien Act.