Gavelocity
Daily slip-opinion summaries for practicing attorneys Updated weekday mornings · 10:30 CT

Illinois appellate courts

20 opinions this month · page 2 Civil
Tuesday, August 11, 2026 2 opinions
2026 IL App (1st) 250549 No. 2026 IL App (1st) 250549

Lee v. Lee

Rule 23 Civil Property Law

  • A tax benefit like section 1031 capital gains deferral can constitute valid consideration for a quitclaim deed conveyance
  • Fiduciary duty between co-shareholders can extend to jointly used real property, but no presumption of fraud arises absent a dominant/servient relationship
  • Useful for business/real estate litigators handling intra-family or closely-held business disputes over property transfers, deed consideration, and fiduciary duty claims
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2026 IL App (1st) 252466 No. 2026 IL App (1st) 252466

In re Marriage of Harrell

Rule 23 Civil Family Law

  • Section 603.10's serious-endangerment remedies are non-exhaustive, giving trial courts broad authority to order temporary relocation to protect a child.
  • Appellant's failure to provide hearing transcripts required presuming the omitted evidence supported the trial court's relocation and endangerment findings.
  • Useful for family law practitioners handling emergency relocation, serious-endangerment, or Rule 306(a)(5) interlocutory appeals where the record is incomplete.
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Monday, August 10, 2026 4 opinions
2026 IL App (3d) 250482 No. 2026 IL App (3d) 250482

In re Marriage of Tompkins

Rule 23 Civil Family Law

  • Events expressly contemplated and priced into a detailed MSA maintenance formula cannot later constitute a 'substantial change in circumstances.'
  • Voluntary lifestyle reductions and modest medical cost increases, unlinked to actual need or ability-to-pay allegations, fail to state a maintenance modification claim.
  • Useful for family law attorneys drafting or litigating maintenance modification petitions involving high-income payors and detailed MSA income-bracket formulas.
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2026 IL App (2d) 260123 No. 2026 IL App (2d) 260123

In re M.K.

Rule 23 Civil Family Law

  • Rule 213 disclosure is satisfied where the opposing party already possesses the witness's name, contact information, and reports detailing the substance of anticipated testimony.
  • Arguments not supported by cited authority, such as claiming discovery obligations differ between the unfitness and best-interest phases of termination proceedings, are forfeited on appeal.
  • Useful for family law and child welfare attorneys litigating discovery disputes and Rule 213 compliance in parental termination and best-interest hearings.
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2026 IL App (1st) 261460 No. 2026 IL App (1st) 261460

Paris v. Chicago Transit Authority

Rule 23 Civil Property Law

  • Public ownership of land alone does not defeat adverse possession; only actual public use of the specific parcel bars the 20-year prescriptive period.
  • A TRO restraining removal of vehicles/structures on disputed land can satisfy section 11-101's specificity requirement via addresses, legal descriptions, and exhibits.
  • Useful for real estate and municipal litigators handling adverse possession claims against transit authorities or other public entities over underused public land.
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2026 IL App (5th) 260234 No. 2026 IL App (5th) 260234

In re S.

Rule 23 Civil Family Law

  • Reasonable progress under 750 ILCS 50/1(D)(m)(ii) is measured objectively, ignoring personal excuses like homelessness or scheduling conflicts.
  • Unresolved housing that blocks required hands-on parenting services and continued residence with a domestic violence victim support unfitness findings.
  • Useful for family law and child welfare attorneys handling termination of parental rights appeals involving reasonable progress and best-interest challenges.
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Friday, August 7, 2026 10 opinions
2026 IL App (5th) 260218 No. 2026 IL App (5th) 260218

In re Harley D.

Rule 23 Civil Family Law

  • Appellate court affirms neglect finding where both parents knowingly and voluntarily stipulated to substance abuse allegations and factual basis.
  • Wardship and DCFS custody upheld where minor's mental health needs and parents' insufficiently demonstrated sobriety justified placement over parental custody.
  • Useful for family law and juvenile dependency practitioners handling Anders-type appeals in neglect, wardship, and parental unfitness proceedings.
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2026 IL App (5th) 241001 No. 2026 IL App (5th) 241001

Dorman v. Madison County

Rule 23 Civil Civil Procedure

  • Appellate court liberally construes notices of appeal, allowing review of orders not precisely dated when procedural progression to final judgment is clear.
  • Fourth successive lawsuit against Madison County dismissed as improper claim splitting because all suits arose from the same operative facts.
  • Useful for civil litigators handling res judicata/claim-splitting defenses and appellate practitioners navigating notice of appeal specificity requirements under Rule 303(b)(2).
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2026 IL App (3d) 250070 No. 2026 IL App (3d) 250070

Village of Bolingbrook v. Illinois Commerce Commission

Rule 23 Civil Administrative Law

  • Arguments not fairly raised in a rehearing application before the ICC are forfeited on appeal, with no discretion to excuse noncompliance.
  • Public comments and unaffordability claims alone do not render Commission-approved utility rates unjust, unreasonable, or unlawful under the Public Utilities Act.
  • Useful for utility/administrative law attorneys challenging ICC rate orders or briefing forfeiture and substantial-evidence standards on appellate review.
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2026 IL App (5th) 241003 No. 2026 IL App (5th) 241003

Dorman v. Madison County

Rule 23 Civil Civil Procedure

  • Refiled Tort Immunity Act claims filed nearly three years post-termination were untimely; continuing violation doctrine did not toll the one-year limitations period.
  • Illinois Savings Statute saved claims only against a defendant dismissed federally for failure to serve/prosecute, not those dismissed for failure to state a claim.
  • Useful for municipal/government litigators and civil defense counsel handling refiled suits, claim-splitting, tort immunity limitations, and Court of Claims jurisdictional defenses.
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2026 IL App (1st) 241677 No. 2026 IL App (1st) 241677

Coughlin v. Johnson

Rule 23 Civil Administrative Law

  • Police Board's discharge of officers for unjustified use of deadly force upheld as supported by manifest weight of the evidence.
  • Disparate treatment claims fail absent 'identical circumstances' or a completely related proceeding involving the comparator officer.
  • Useful for municipal/police discipline attorneys and administrative review practitioners handling police board discharge and comparator-based disparate treatment arguments.
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2026 IL App (1st) 241647 No. 2026 IL App (1st) 241647

Arroyo v. City of Chicago

Rule 23 Civil Contract Law

  • Promissory estoppel fails against a municipality when the promise came from an employee lacking authority to sell city land.
  • Reliance on an unauthorized city official's oral promise is presumptively unreasonable, defeating both promissory estoppel and statute of frauds exceptions.
  • Useful for municipal and real estate attorneys handling disputes over unauthorized government employee promises or failed land deals.
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2026 IL App (1st) 250641 No. 2026 IL App (1st) 250641

Wright v. Illinois State Police

Rule 23 Civil Administrative Law

  • Court affirms denial of FOID card relief where applicant failed to disclose felony firearm convictions on his application.
  • Law enforcement agencies may consider expunged or sealed records when reviewing FOID card applications under section 12(a) exemption.
  • Useful for attorneys handling FOID card appeals, firearm rights restoration petitions, or expungement/sealing disputes involving licensing agencies.
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2026 IL App (1st) 252583 No. 2026 IL App (1st) 252583

Willow Bridge Property v. Rogers

Rule 23 Civil Real Estate Law

  • Motion to vacate a default judgment is deemed abandoned if not pursued or brought to the court's attention for two months.
  • Appellant's failure to provide a hearing transcript or Rule 323 substitute is fatal to challenging a trial court's discretionary ruling on appeal.
  • Useful for eviction/landlord-tenant practitioners and appellate counsel handling pro se defaults, mootness challenges, and inadequate-record issues.
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2026 IL App (1st) 252309 No. 2026 IL App (1st) 252309

Dyson v. Balanoff

Rule 23 Civil Civil Procedure

  • Appellate court dismissed appeal as premature because a timely postjudgment motion remained unresolved in the circuit court.
  • Filing a notice of appeal does not abandon a pending postjudgment motion under Rule 303(a)(2); jurisdiction requires disposition first.
  • Useful for civil litigators and pro se practitioners navigating appeal timing after filing postjudgment motions to vacate dismissals.
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2026 IL App (1st) 240677 No. 2026 IL App (1st) 240677

In re Estate of Glass

Rule 23 Civil Probate and Estate Law

  • Probate courts retain broad discretion to award only 'reasonable' fees, even to retained (not court-appointed) counsel under a contract.
  • Excessive email billing, unnecessary associate work, and above-market hourly rates justify substantial fee reductions without abuse of discretion.
  • Useful for probate/guardianship attorneys litigating fee petitions and for any practitioner defending or challenging court-ordered fee reductions.
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Wednesday, August 5, 2026 2 opinions
2026 IL App (4th) 260418 No. 2026 IL App (4th) 260418

In re K.D.

Rule 23 Civil Family Law

  • Late-established paternity does not excuse a father's failure to visit or inquire about a child's welfare before DNA confirmation.
  • Unfitness and best-interests hearings may be held on the same day so long as evidence presentation is properly bifurcated.
  • Useful for family law and child welfare practitioners handling termination of parental rights appeals and jurisdictional timing issues.
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2026 IL App (4th) 260420 No. 2026 IL App (4th) 260420

In re K.D.

Rule 23 Civil Family Law

  • Denial of day-of-trial continuance in termination case upheld where respondent showed no good cause under Rule 901(c).
  • Generalized claims of unpreparedness, without identifying specific witnesses or evidence, do not justify a trial-day continuance.
  • Useful for family law and child welfare attorneys handling continuance requests in juvenile neglect and termination proceedings.
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Tuesday, August 4, 2026 2 opinions
2026 IL App (1st) 250894 No. 2026 IL App (1st) 250894

Vasquez v. Aguilar

Rule 23 Civil Family Law

  • Trial courts must make express findings under section 214(c)(3) of the IDVA before entering a plenary order of protection, or it will be reversed.
  • A respondent may forgo immediate interlocutory appeal of an OP and instead appeal within 30 days of denial of a timely post-judgment motion.
  • Useful for family law and domestic relations attorneys litigating orders of protection, appellate jurisdiction/timing issues, and mootness in expired-OP appeals.
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