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12 Illinois opinions name it 1 courts 1987–2025 6 in the last five years
The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
In re Marriage of Hamiltongreen1 sentence2025See In re Marriage of Hamilton, 2019 IL App (5th) 170295, ¶ 76 (providing that a dissipation claim should be considered if it complies with the express requirements of the Act and comports with notions of fairness). | 1 | 1 |
In re Marriage of Berberetgreen1 sentence2024Also, while the trial court found that Edward’s use of the funds to pay an unidentified amount in attorney fees amounted to dissipation (see In re Marriage of Berberet, 2012 IL App (4th) 110749, ¶ 58 (“The use of marital assets to pay fees to one’s attorney for the costs of the divorce constitutes dissipation of marital assets.”)), it nonetheless declined to order Edward to reimburse Leslie, reasoning that the case was heavily litigated and both sides incurred substantial legal fees. | 1 | 1 |
In re Marriage of Barnettgreen1 sentence2022It is true, in the context of a dissipation claim, “[a]n enormous potential for prejudice lies if financial information is missing due to *** [a] failure to comply with discovery.” In re Marriage of Brown, 2015 IL (5th) 140062, ¶ 58 (quoting In re Marriage of Barnett, 344 Ill. | 1 | 1 |
In Re Marriage of Millergreen1 sentence2020Miller, 342 Ill. App. 3d at 994 (“Although a spouse may not necessarily derive a personal benefit from the acts that constitute dissipation [citation], expenditures that form the basis for dissipation should have some detrimental effect upon the marital estate.”). | 1 | 1 |
In Re Marriage of O'Neillgreen1 sentence2019In re Marriage of O’Neill, 138 Ill. 2d 487, 497 (1990). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re Marriage of Brown
green
1 sentence2025Id. ¶ 53 Jacob argues that Caitlin failed to make a prima facie case of dissipation. | 1 | 2025–2025 |
Flores v. Aon Corp.
green
1 sentence2025Plaintiff also cites Flores v. Aon Corp., 2023 IL App (1st) 230140, ¶ 24 , which analyzed the Information Act and held that the Aon Corporation had a common-law duty to protect the personal information of its clients in addition to its duty under the Information Act. ¶ 41 Plaintiff contends we should analyze the absolute litigation privilege through the “new prism” of the Information Act and Flores, which has elevated and provided new protections for individuals’ privacy rights, and hold that defendants here “should not be protected in their unbridled investigations into 35 years of highly sen | 1 | 2025–2025 |
In Re Marriage of Ignatius
green
1 sentence2024This interpretation comports not only with the fairness considerations discussed above, but also with well-established precedent concerning the trial court’s limited discretion in dissolution proceedings, where its powers are “entirely statutory in nature and origin.” In re Marriage of Blum and Koster, 377 Ill. App. 3d at 526 ; In re Marriage of Ignatius, 338 Ill. App. 3d at 657 . | 1 | 2024–2024 |
In re Marriage of Blum
green
1 sentence2024This interpretation comports not only with the fairness considerations discussed above, but also with well-established precedent concerning the trial court’s limited discretion in dissolution proceedings, where its powers are “entirely statutory in nature and origin.” In re Marriage of Blum and Koster, 377 Ill. App. 3d at 526 ; In re Marriage of Ignatius, 338 Ill. App. 3d at 657 . | 1 | 2024–2024 |
In Re Marriage of Frey
green
1 sentence2020“Dissipation is the use of marital property for the sole benefit of one of the spouses for a purpose unrelated to the marriage occurring at a time that the marriage is undergoing an irreconcilable breakdown.” In re Marriage of Frey, 258 Ill. | 1 | 2020–2020 |
In Re Marriage of Seversen
green
1 sentence1994During the dissolution process, the needs of each party remain unchanged yet the disparate application of the dissipation principle penalizes one spouse while it condones the same type of expenditures for the other spouse.” Seversen, 228 Ill. | 1 | 1994–1994 |
In Re Marriage of Smith
green
1 sentence1992We continue to adhere to our prior denunciation of dissipation as “an unacceptable practice that will not be sanctioned.” (In re Marriage of Smith (1983), 114 Ill. | 1 | 1992–1992 |
In re Marriage of Sevon
green
2 sentences1987In re Marriage of Sevon (1983), 117 Ill. 1987In re Marriage of Sevon (1983), 117 Ill. | 1 | 1987–1987 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.