2026 IL App (3d) 250482 No. 2026 IL App (3d) 250482
Rule 23 · Civil —Family Law
- ¶1 Events expressly contemplated and priced into a detailed MSA maintenance formula cannot later constitute a 'substantial change in circumstances.'
- ¶2 Voluntary lifestyle reductions and modest medical cost increases, unlinked to actual need or ability-to-pay allegations, fail to state a maintenance modification claim.
- ¶3 Useful for family law attorneys drafting or litigating maintenance modification petitions involving high-income payors and detailed MSA income-bracket formulas.
2026 IL App (2d) 250208 No. 2026 IL App (2d) 250208
Rule 23 · Criminal —Criminal Procedure
- ¶1 Sentencing courts may draw reasonable inferences from evidence, including causation of injuries, if supported by factual antecedents in the record
- ¶2 Even an improper aggravating factor won't require resentencing if the record shows it carried insignificant weight compared to proper factors
- ¶3 Useful for criminal defense and appellate attorneys challenging sentencing decisions based on alleged improper aggravating factors or seeking remand for resentencing
2026 IL App (3d) 250218 No. 2026 IL App (3d) 250218
Opinion · Criminal —Violent Crimes
- ¶1 Prior reckless discharge of a firearm conviction is not automatically a forcible felony; State must prove defendant contemplated or was willing to use force.
- ¶2 Police report facts not stipulated to or proven through testimony are inadmissible hearsay and cannot establish a forcible felony predicate.
- ¶3 Useful for criminal defense and appellate attorneys litigating AHC/UPWF predicate offenses, hearsay objections, presentence credit, and merged-count sentencing issues.
2026 IL App (2d) 260123 No. 2026 IL App (2d) 260123
Rule 23 · Civil —Family Law
- ¶1 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.
- ¶2 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.
- ¶3 Useful for family law and child welfare attorneys litigating discovery disputes and Rule 213 compliance in parental termination and best-interest hearings.
2026 IL App (5th) 240302 No. 2026 IL App (5th) 240302
Rule 23 · Criminal —Criminal Procedure
- ¶1 Section 122-2 requires witness affidavits (not the defendant's own) or a particularized explanation for their absence, or dismissal is warranted.
- ¶2 General claims that incarceration made evidence-gathering difficult do not excuse the failure to attach specific missing witness affidavits.
- ¶3 Useful for criminal defense and postconviction practitioners drafting or defending first-stage pro se petitions alleging failure to call witnesses.
2026 IL App (1st) 261460 No. 2026 IL App (1st) 261460
Rule 23 · Civil —Property Law
- ¶1 Public ownership of land alone does not defeat adverse possession; only actual public use of the specific parcel bars the 20-year prescriptive period.
- ¶2 A TRO restraining removal of vehicles/structures on disputed land can satisfy section 11-101's specificity requirement via addresses, legal descriptions, and exhibits.
- ¶3 Useful for real estate and municipal litigators handling adverse possession claims against transit authorities or other public entities over underused public land.
2026 IL App (5th) 260234 No. 2026 IL App (5th) 260234
Rule 23 · Civil —Family Law
- ¶1 Reasonable progress under 750 ILCS 50/1(D)(m)(ii) is measured objectively, ignoring personal excuses like homelessness or scheduling conflicts.
- ¶2 Unresolved housing that blocks required hands-on parenting services and continued residence with a domestic violence victim support unfitness findings.
- ¶3 Useful for family law and child welfare attorneys handling termination of parental rights appeals involving reasonable progress and best-interest challenges.
2026 IL App (1st) 250285 No. 2026 IL App (1st) 250285
Rule 23 · Criminal —Criminal Procedure
- ¶1 Codefendant affidavits obtained after their guilty pleas became final are not newly discovered evidence for actual-innocence claims.
- ¶2 A guilty plea waives the Fifth Amendment privilege once the 30-day withdrawal period expires, making prior codefendant testimony available earlier.
- ¶3 Useful for criminal defense and postconviction attorneys evaluating successive petitions based on codefendant affidavits or delayed exculpatory testimony.