Jorge Luis Cortes-Yepez filed a pro se petition for a Stalking No Contact Order (SNCO) against his then-coworker Gerardo Avelar in Cook County, alleging multiple incidents of violent and harassing workplace conduct, including Avelar placing a plastic bag over petitioner's head twice while threatening to kill him, punching him, throwing a clam at his face, and subjecting him to homophobic harassment. The trial court entered an emergency SNCO, but at the plenary hearing denied a permanent order solely because the parties no longer worked together, citing 'insufficient evidence' on that basis. Petitioner appealed.

The First District Appellate Court reversed on two grounds. First, applying de novo review, the court held that section 80(a) of the Stalking No Contact Order Act — providing that a stalking no contact order 'shall issue' upon a finding that petitioner was a victim of stalking — imposes a mandatory obligation, not discretionary authority. Drawing on the plain meaning of 'shall,' the Act's stated purpose, and the analogous holding in Sanchez v. Torres under the Illinois Domestic Violence Act, the court found no room for judicial discretion once stalking is established. Second, applying manifest weight review, the court found the trial court had effectively determined stalking occurred, and the parties' changed employment status was legally insufficient to override the Act's mandatory directive.

The court remanded with direction to enter a two-year plenary SNCO. Attorneys handling protective order matters should note that once a court finds stalking by a preponderance of the evidence, issuance of an SNCO is non-discretionary, and changed circumstances between the parties do not defeat that obligation.

In People v. Simmons, the defendant was convicted after a bench trial of four counts of aggravated criminal sexual abuse under 720 ILCS 5/11-1.60(b) and (d) for pinching the nipple of the complaining witness, B.C., on four occasions. The circuit court sentenced him to two years' probation and required sex offender registration. Defendant appealed, arguing the State failed to prove he acted for the purpose of sexual gratification or arousal — the element that elevates the touching to 'sexual conduct' under the statute.

The First District Appellate Court affirmed, applying the Jackson v. Virginia sufficiency standard and finding ample circumstantial evidence to support the conviction. The court pointed to the repeated nature of the touching, defendant's subsequent kissing of B.C.'s neck accompanied by a grunting noise, a prior incident of breast contact, B.C.'s immediate report to her school counselor, and defendant's own law enforcement statement that he had 'feelings' during the touching and acknowledged it was wrong. Notably, the circuit court did not even rely on defendant's ambiguous interview statements, instead grounding its finding in B.C.'s testimony, which it deemed 'extremely credible,' and the corroborating account of the school social worker.

The court rejected defendant's argument that the absence of aggravating factors — such as sexual statements, under-clothing contact, force, or a non-public setting — negated the sexual gratification finding, clarifying that no formal checklist governs the analysis. Credibility determinations and reasonable inferences drawn from conduct remain exclusively within the province of the trier of fact.

Ebony Edwards was convicted by a Cook County jury of aggravated battery of a peace officer under 720 ILCS 5/12-3.05(d)(4)(i), based on allegations that she struck Chicago police sergeant Tellez-Sandoval in the mouth before her arrest, chipping his front teeth. She was acquitted on a companion count predicated on bodily harm and sentenced to two years of probation with 15 hours of community service. After the circuit court denied her motion for a new trial, Edwards appealed, arguing that video evidence contradicted the officers' testimony and was therefore insufficient to sustain her conviction.

The Illinois Appellate Court, First District, affirmed. Applying the familiar Jackson v. Virginia standard, the court held that a rational trier of fact could have found the elements of aggravated battery beyond a reasonable doubt. The court rejected Edwards's argument that POD camera footage contradicted the officers' accounts, explaining that the low-resolution footage captured the incident from behind the defendant, obscuring her arms and hands at the critical moment. The footage therefore omitted, rather than contradicted, the alleged contact. The court further noted that photographic evidence of Tellez-Sandoval's chipped teeth and his subsequent dental treatment independently corroborated the officers' testimony.

For practicing attorneys, this decision reinforces that incomplete or ambiguous video evidence does not automatically undermine witness credibility or warrant reversal. Courts will distinguish between video that contradicts testimony and video that simply fails to capture the disputed conduct, leaving credibility determinations to the jury.

Elijah Davis was convicted by a Cook County jury of aggravated battery in a public place of accommodation and sentenced to 12 months' probation following an altercation with Jorge Garcia. The case involved two separate fights captured on surveillance video. Davis argued on appeal that the State failed to disprove beyond a reasonable doubt that he acted in self-defense, warranting reversal of his conviction.

The Illinois First District Appellate Court affirmed, applying the standard of whether any rational trier of fact could find the State disproved self-defense beyond a reasonable doubt. The court emphasized that self-defense is an affirmative defense requiring the defendant to present some evidence of six elements, and that the State defeats the claim by negating any single element. Here, the court found the evidence negated multiple elements as to the second fight: Davis struck Garcia first, repeatedly beat him, dragged him from the door, and stomped on his face, neck, and chest while Garcia lay on the ground — conduct that rendered Davis the aggressor, negated any imminent danger, and made his belief in the necessity of such force objectively unreasonable. The court deferred to the jury's credibility determinations and its resolution of conflicting evidence.

For practicing attorneys, this case reinforces that excessive force — particularly continuing to attack a grounded, non-threatening victim — can independently defeat a self-defense claim by transforming the defendant into the aggressor and eliminating the imminence and reasonableness elements.

Shade George Ghanayem, acting as attorney-in-fact for the record owner of property at 4857 West Division Street in Chicago, filed a petition in August 2024 challenging the validity of a Certificate of Purchase, alleging it had been fraudulently altered. While that petition was pending, a separate Cook County Division proceeding resulted in a sale-in-error order on September 26, 2024, which vacated the tax sale and directed a full refund to the certificate holder, Fundpality II, LLC. The circuit court dismissed Ghanayem's petition with prejudice on grounds of mootness, lack of standing, and duplicativeness, and denied leave to file an amended petition.

The First District affirmed solely on mootness grounds, declining to address standing or duplicativeness. Reviewing de novo, the court held that because the sale-in-error order nullified the Certificate and the funds were returned, any judicial declaration regarding the alleged forgery would have no practical legal effect. The court also rejected Ghanayem's argument that the alleged forgery rendered the sale-in-error order void, reasoning that a court's jurisdiction does not depend on the legal sufficiency of the underlying pleadings or documents, and thus an alleged defect in the Certificate could not strip the County Division court of authority to enter the order.

Practically, this decision confirms that once a tax sale is vacated through a sale-in-error order and funds are refunded, collateral challenges to the certificate of purchase are moot and cannot be revived through amended pleadings. Attorneys should also note that failure to provide a hearing transcript on appeal will trigger the Foutch presumption that the circuit court's order was legally sufficient.

In August 2025, the State filed petitions for adjudication of wardship in Rock Island County regarding five children of Tiffany R. The trial court found the eldest child, T.R., abused and neglected, and found the four younger children neglected, making all five wards of the court. Following a January 2026 dispositional hearing, the court found Tiffany unable to care for the children, approved recommended services, and set reunification as the permanency goal for the younger children, who remained placed with their father Morrio R. Tiffany appealed only the neglect findings and dispositional orders concerning the four younger children.

On appeal, the Fourth District affirmed both the neglect findings and the dispositional orders. As to neglect, the court held that Tiffany's severe physical assault of T.R. in the presence of the younger children — causing significant visible injuries — and her subsequent abandonment of T.R. on an interstate without shoes or a phone, provided sufficient evidence of an injurious environment. The court applied the statutory rule permitting proof of abuse or neglect of one child as evidence of neglect of siblings, and emphasized that courts need not wait for each child to suffer harm before acting. Tiffany's continued characterization of the incident as a 'mutual altercation' further evidenced a lack of accountability.

On the dispositional challenge, the court found no abuse of discretion, reasoning that requiring minimal service compliance before returning children to unfettered parental supervision was neither arbitrary nor unreasonable given the circumstances. The court also noted Tiffany's failure to cite supporting authority or adequately develop her dispositional argument.

Plaintiff Kameron Huckleby filed a pro se complaint in Cook County Circuit Court against multiple defendants, including Judge William Gamboney, alleging constitutional violations, wrongful arrest, malicious prosecution, and inhumane incarceration conditions arising from his COVID-era incarceration. On July 10, 2024, the trial court granted Judge Gamboney's amended motion to dismiss with prejudice, but the order addressed only Gamboney and did not reference the remaining defendants—Thomas Dart, Kimberly Foxx, and the Cook County Department of Corrections—nor did it include a Rule 304(a) finding. More than 30 days later, on February 4, 2025, plaintiff filed a motion to reinstate the case, which the trial court struck as untimely on March 5, 2025. Plaintiff appealed from that March 5 order.

The First District dismissed the appeal for lack of jurisdiction. The court explained that the July 10, 2024 order was not a final judgment because it disposed of the case as to only one defendant in a multi-party action without a Rule 304(a) finding, making it non-appealable until the entire action was terminated. Because plaintiff's motion to reinstate was filed more than 30 days after a non-final order, it was untimely as a postjudgment motion, and an appeal from the striking of that motion provided no jurisdictional basis. The court declined to separately dismiss for plaintiff's failure to comply with Rule 341(h) briefing requirements, though it acknowledged discretion to do so.

For practicing attorneys, this decision reinforces two critical Illinois appellate practice rules: partial dismissals in multi-party cases require a Rule 304(a) finding to be immediately appealable, and postjudgment motions must be filed within 30 days of the relevant order to preserve appellate jurisdiction. Failure to obtain a Rule 304(a) finding can leave parties without a clear appellate pathway until the entire case concludes.

Marcus Bell was convicted of attempt first degree murder after a bench trial and sentenced to 30 years. His postconviction petition, filed by privately retained counsel, alleged ineffective assistance of trial counsel for failing to file a motion to suppress an eyewitness identification and for failing to call an expert on eyewitness reliability. The circuit court granted the State's motion to dismiss at the second stage, and Bell appealed.

The First District reversed and remanded, finding that postconviction counsel rendered unreasonable assistance by failing to attach an expert affidavit or report to support the eyewitness identification claim. Because counsel was privately retained rather than appointed, Rule 651(c) did not apply; instead, the court applied a Strickland-like analysis requiring a showing of both deficient performance and prejudice. The court held that attaching general research articles on eyewitness reliability was insufficient — without a case-specific expert report, there were no particular facts for the circuit court to credit at the second stage, rendering the claim impermissibly speculative.

On prejudice, the court relied on People v. Lerma and distinguished People v. Elliott, emphasizing that the State's case rested entirely on a single, significantly impeached eyewitness with no prior familiarity with Bell and no corroborating physical evidence. Under those circumstances, the court found a reasonable probability that attaching a proper expert report would have changed the outcome of the postconviction proceeding. The court declined to reach the merits of either underlying ineffective assistance claim, treating the postconviction counsel issue as dispositive.

Gregory Sherman was convicted of being an armed habitual criminal (AHC) following a second jury trial in Cook County after a July 2022 incident at a Chicago Shell gas station. The State's evidence included eyewitness testimony from a store employee who heard a loud bang, observed a flash near Sherman's legs, and found a bullet fragment on the floor, as well as surveillance video corroborating that account and medical records confirming Sherman was treated for gunshot wounds. Sherman, representing himself pro se, was sentenced to 10 years' imprisonment and appealed on four grounds: sufficiency of the evidence, improper hearsay testimony, the constitutionality of his arrest pursuant to an investigative alert, and the facial constitutionality of the AHC statute under the Second Amendment.

The First District affirmed on all counts. The court found sufficient evidence of firearm possession based on the eyewitness, corroborating video, and medical evidence. Although the court acknowledged that officers improperly introduced hearsay references to a 'shooting' and the 'peacefulness' of Milwaukee Avenue, defendant failed to preserve the errors and the evidence was not closely balanced, defeating plain error review. On the investigative alert issue, the court applied the Illinois Supreme Court's binding decision in People v. Clark, 2024 IL 127838, which expressly upheld warrantless felony arrests based on probable cause via investigative alerts under the Illinois Constitution.

On the Second Amendment challenge, the court held the AHC statute facially constitutional under the Bruen framework, concluding that felons are not 'law-abiding citizens' and therefore their conduct is not covered by the Second Amendment's plain text, making the first Bruen step dispositive. The court noted that even under an alternative analytical approach examining historical tradition at step two, the result would be the same. This decision is significant for practitioners handling AHC prosecutions, Second Amendment challenges to felon-in-possession statutes, and suppression motions based on investigative alerts.

Michael Gracia was convicted after a severed but simultaneous bench trial of two counts of attempted first degree murder for a shooting involving victims Sergio Cabral and Miguel Sierra, and sentenced to concurrent terms of 31 and 26 years. On direct appeal, Gracia challenged the sufficiency of the evidence identifying him as the shooter, the sufficiency of evidence supporting specific intent to kill Sierra, and the effectiveness of trial counsel for failing to object to post-shooting text messages sent by codefendant Athans.

The First District affirmed on all three issues. On identification, the court declined to apply a heightened de novo review under Neil v. Biggers, expressly following the Illinois Supreme Court's clarification in People v. Johnson, 2026 IL 131337, that the Biggers factors inform the totality of circumstances but cannot expand appellate review beyond the rational-trier-of-fact standard. The court credited the trial judge's determination that Cabral's consistent identification of Gracia as the passenger, combined with Sierra's prior statements to police that the passenger was the shooter — corroborated by surveillance footage contradicting Sierra's trial recantation — was sufficient. On specific intent as to Sierra, the court found the audio sequence of shots, physical evidence of the shot-out PT Cruiser window, and detective reports supported a reasonable inference that Sierra was an intended target.

On ineffective assistance, the court held that because the trials were severed bench trials, Bruton v. United States was inapplicable, and the well-established presumption that a bench trial judge considers only admissible evidence as to each defendant was not rebutted by the record. Counsel had no basis to object, and no prejudice was shown.

Antrell Johnson was convicted by a Cook County jury of first degree murder and personally discharging a firearm causing death. At trial, an alibi witness named Myles testified that Johnson was with her, approximately one hour away from the crime scene, at the time of the shooting. In a posttrial motion, new counsel argued trial counsel was ineffective for failing to call Johnson's cousin, Vernon Johnson, as a second alibi witness. The trial court denied the motion. On remand from the Illinois Supreme Court, the First District addressed the sole remaining issue of whether trial counsel's failure to call Vernon constituted ineffective assistance.

Applying Strickland, the court proceeded directly to the prejudice prong and found it dispositive. The court identified three reasons Vernon's testimony would not have created a reasonable probability of a different outcome: Vernon's testimony was vague and lacked particularity as to dates and events; as Johnson's close cousin who spoke with him daily yet never contacted authorities, his credibility would have been minimal; and most critically, Vernon's account directly contradicted Myles's alibi testimony. Vernon placed Johnson at the grandmother's house at 7:30 p.m., while Myles testified Johnson was with her an hour away at that same time. This internal contradiction would have undermined rather than bolstered the defense.

For practicing attorneys, this case reinforces that an uncalled witness whose testimony conflicts with existing trial testimony cannot satisfy Strickland's prejudice prong, even where partial corroboration exists. Defense counsel should carefully vet alibi witnesses for consistency before presenting multiple alibi accounts.

This opinion from Opinion was filed on 2026-06-05. The case "People v. Wright, 2026 IL App (1st) 240238" (Docket: 2026 IL App (1st) 240238) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.

Johnny Conwell was convicted of two counts of first degree murder and one count of attempted first degree murder following a bench trial in Cook County. He was 18 years and one month old at the time of the offenses and received a mandatory natural life sentence without the possibility of parole. His 2002 postconviction petition was summarily dismissed. Nearly two decades later, Conwell sought leave to file a successive postconviction petition arguing his sentence violated the proportionate penalties clause of the Illinois Constitution as applied to him. The circuit court granted the State's motion to dismiss, and Conwell appealed.

The First District reversed, holding that Conwell made a prima facie showing of both cause and prejudice sufficient to allow the successive petition to proceed. On cause, the court found that no viable legal pathway existed in 2002 for an emerging adult to raise an as-applied proportionate penalties challenge grounded in youth-related characteristics, particularly where the sentence was mandatory, and that Conwell's documented psychological conditions — including schizophrenia, PTSD, and an IQ of 76 — further impeded earlier litigation of the claim. On prejudice, the court emphasized that the original sentencing judge expressly acknowledged on the record that he was 'precluded by law' from imposing a term-of-years sentence, meaning youth-related mitigation could not be given meaningful effect.

The court drew a material distinction between mandatory and discretionary life sentences, holding that People v. Dorsey, Clark, and Moore — which involved sentencing courts retaining discretion — do not control where a court is structurally barred from considering youth. The opinion expressly does not invalidate Conwell's sentence or expand Miller, but permits further factual development of the as-applied claim. Defense attorneys handling similar cases should note the significance of the mandatory sentencing structure and the original sentencing judge's on-record acknowledgment of his lack of discretion.

Five siblings inherited a Palos Hills townhome through a Transfer on Death Instrument. Four sought partition by sale under the Illinois Uniform Partition of Heirs Property Act (755 ILCS 75/1 et seq.); the fifth, Susan McDunn, opposed the sale. The dispute was resolved when Susan purchased her siblings' interests for $160,000. The Cook County circuit court then apportioned attorney fees and costs under section 12 of the Act, ordering Susan to bear 40% of plaintiffs' $19,110 in attorney fees while awarding her only $1,500 of the $5,256.25 she sought for her own outside counsel. Susan appealed pro se, challenging the fee apportionment, the reasonableness of plaintiffs' fees, her limited fee award, denial of credits for lost profits and a tax refund, and denial of her motion to strike disparaging language from plaintiffs' filings.

The appellate court affirmed all rulings, holding that abuse of discretion is the proper standard of review under section 12's 'just and equitable' language. The court found no abuse of discretion in the 40% apportionment, noting that section 12 contains no language shielding a party from fee liability merely because she contested the action. The court further held that Susan's defenses—pointing out mislabeled parties, an uncited statute, and a scrivener's error in the property PIN—were purely technical and did not qualify as 'good and substantial defenses' under section 12, which requires defenses that actually affect the parties' interests in the property.

For practitioners, this decision clarifies that vigorous but technically-focused opposition in heirs property partition cases will not insulate a co-owner from fee apportionment, and that incomplete appellate records and Rule 341(h)(7) briefing failures will independently doom an appeal.

Irene Kogan, proceeding pro se, filed a complaint in the Circuit Court of Cook County against attorney Todd McCartney alleging fraud and breach of contract, claiming she paid a $2,000 retainer for representation in a contingency case that McCartney never pursued. Following a bench trial in January 2025, the trial court awarded Kogan $750. She appealed seeking the remaining $1,250, arguing McCartney failed to produce documentation of his representation at trial.

The First District affirmed, primarily because Kogan failed to provide a transcript of the trial proceedings or any proper substitute under Illinois Supreme Court Rule 323. Without a record of the evidence presented, arguments made, or the basis for the trial court's ruling, the appellate court had no basis to disturb the judgment and applied the well-established presumption from Foutch v. O'Bryant that the trial court acted in conformity with the law with a sufficient factual basis. The court also refused to consider approximately 40 pages of text messages and emails Kogan attached to her brief's appendix, reaffirming that parties may not supplement the appellate record through brief appendices.

Although Kogan's brief violated Rule 341(h) — lacking jurisdictional statements, legal authority, record citations, and a proper argument section — the court declined to dismiss on that basis alone, noting McCartney's brief was similarly deficient. The case underscores the critical importance of securing a trial transcript before filing a notice of appeal and ensuring that all evidentiary materials are properly admitted into the record below.

Lamont Brown was convicted of first degree murder in 2008 and sentenced to 60 years. After his direct appeal and multiple collateral attacks failed, Brown filed a 2024 motion for leave to file a successive postconviction petition asserting actual innocence. His claim rested on a 2023 book published by purported eyewitness Rayvon Parker — who identified a different perpetrator — and prison messages from Parker. The Cook County circuit court denied the motion, and Brown appealed.

The First District reversed on all substantive issues. The court held that the book's absence from the filed record was not fatal given Brown's verified petition and corroborating circumstances, and that the lack of a formal affidavit from Parker was excused because the book and messages independently corroborated his account and appointed counsel could obtain an affidavit at the second stage. The court further held that Parker's account was newly discovered because Brown's pre-trial investigator had interviewed Parker, who at that time denied witnessing the murder — meaning no amount of due diligence could have compelled earlier disclosure. Critically, Parker's 2007 affidavit denying he witnessed the shooting was deemed merely a prior inconsistent statement affecting credibility, not a positive rebuttal precluding relief at the pleading stage.

This decision is significant for defense counsel because it clarifies that technical evidentiary gaps — a missing exhibit, no affidavit — will not automatically doom a successive petition at the leave-to-file stage, and that a witness's prior denial does not categorically foreclose an actual innocence claim based on that witness's later exonerating account.

Essie Nooner was convicted by jury of first degree murder and attempted first degree murder under an accountability theory and originally sentenced to 66 years. On his first direct appeal, the appellate court reversed and remanded solely for resentencing after finding the trial court had misapprehended the evidence. On remand, a different judge imposed a total of 56 years — the statutory minimum for an adult — consisting of consecutive terms with mandatory 15-year firearm enhancements. Nooner appealed again, raising three issues: (1) that original appellate counsel was ineffective for failing to challenge sufficiency of the evidence; (2) that his sentence violated the proportionate penalties clause given his youth, trauma, and limited culpability; and (3) that the circuit court abused its discretion by declining to sentence him as a juvenile.

The appellate court affirmed on all three issues. It held that a second direct appeal following a limited resentencing remand is not the proper vehicle for an ineffective assistance of appellate counsel claim, which belongs in a postconviction petition. On the constitutional challenge, the court found that because Nooner is eligible for parole after 20 years under 730 ILCS 5/5-4.5-115(b), he faces no de facto life sentence, and mandatory firearm enhancements do not shock the moral sense of the community. The court also upheld the circuit court's rejection of defense expert Dr. Garbarino's opinion that Nooner was developmentally a juvenile, citing contradictions between the PSIs and the expert's limited, unverified evaluation.

This decision is significant for defense attorneys navigating resentencing remands and proportionate penalties clause arguments for young adult offenders. It clarifies that the scope of a second direct appeal is strictly limited to issues arising from the resentencing proceeding itself, and that parole eligibility under the 2024 statute is a critical factor in defeating de facto life sentence arguments.

Elliott Robinson was convicted of first degree murder following a jury trial in Cook County and sentenced to 48 years' imprisonment. After his conviction was affirmed on direct appeal, he filed a postconviction petition raising actual innocence, ineffective assistance of appellate counsel, and a proportionate penalties clause violation. The circuit court dismissed the actual innocence and proportionate penalties claims at the second stage and denied the ineffective assistance claim after a third-stage evidentiary hearing. Robinson appealed all three rulings.

The First District affirmed the denial of the ineffective assistance claim, finding no prejudice because the trial evidence was not closely balanced — supported by a dying declaration, voting records, defendant's own admission to being present, a witness identification, and toolmark evidence — and no deficient performance because appellate counsel had considered the issue and exercised professional judgment in pursuing stronger claims. However, the court reversed the second-stage dismissals of both the actual innocence and proportionate penalties claims. Applying the standard from People v. Robinson, 2020 IL 123849, the court held that new witness affidavits identifying a different shooter and Dr. Garbarino's developmental psychology report were not 'positively rebutted' by the trial record, meaning it was not clear that no fact finder could ever accept their truth. Both claims were remanded for third-stage evidentiary hearings.

Practically, this decision reinforces that contradictions between new postconviction evidence and the trial record do not automatically constitute positive rebuttal at the second stage, and that as-applied Miller-type proportionate penalties claims by young adult offenders are properly developed and raised in initial postconviction petitions.

William Graft, Sr. and his brother Michael Graft, Jr. were co-owners of two real estate development entities that undertook the Tallgrass residential development in Barrington, Illinois. After Harris Bank filed a foreclosure action in 2009 on over $13.5 million in outstanding debt, William filed a cross-complaint alleging Michael breached fiduciary duties by concealing a loan default, entering a secret consent-foreclosure agreement with Harris Bank, and selling a lot below the agreed price. Following a bench trial, the trial court found Michael had breached his fiduciary duties but that those breaches did not proximately cause the entities' injuries. William appealed both that ruling and a 2019 Cook County order denying him leave to file a third amended complaint.

The appellate court affirmed on all three issues. On proximate cause, the court held that the trial court's finding was not against the manifest weight of the evidence because William's expert testimony on bridge loan availability depended entirely on an appraisal the trial court found unreliable — one that adopted 2006 peak-market valuations, used no comparable Lake County sales, ignored litigation effects, and assumed an ahistorical lot-sales rate. On jurisdiction, the court held that consolidation of the separate actions into a single suit caused each case to lose its individual identity, making the 2019 order reviewable upon final resolution in 2025. On the motion to amend, the court found William forfeited his arguments by failing to adequately brief the Loyola factors under Rule 341(h)(7).

This decision is significant for business litigators because it underscores that expert testimony in fiduciary duty cases must rest on independently reliable foundations, and that inadequate appellate briefing on multi-factor tests will result in forfeiture regardless of the underlying merits.

This opinion from Rule 23 was filed on 2026-06-02. The case "In re Marriage of Seyl, 2026 IL App (2d) 240719" (Docket: 2026 IL App (2d) 240719) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.