In re Marriage of Fritschle

NOTICE 2026 IL App (5th) 250951-U NOTICE Decision filed 11/09/26. The This order was filed under text of this decision may be NO. 5-25-0951 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS FIFTH DISTRICT ______________________________________________________________________________ In re MARRIAGE OF ) Appeal from the ) Circuit Court of GEORGE R. FRITSCHLE, ) Richland County. ) Petitioner-Appellant and Cross-Appellee, ) ) and ) No. 23-DN-32 ) JILL K. FRITSCHLE, ) Honorable ) Lindsey D Waldrop, Respondent-Appellee and Cross-Appellant. ) Judge, presiding. ______________________________________________________________________________ JUSTICE BOLLINGER delivered the judgment of the court. Presiding Justice Cates and Justice Clarke concurred in the judgment. ORDER ¶1 Held: (1) It was not an abuse of discretion for the trial court to order George to pay maintenance to Jill; (2) the trial court’s determination of certain of Jill’s bank accounts as nonmarital was not contrary to the manifest weight of the evidence; (3) the trial court’s reliance on both appraisals of the marital residence was not against the manifest weight of the evidence; (4) the trial court did not abuse its discretion in its division of property; and (5) the trial court did abuse its discretion in ordering that Jill’s attorney fees be paid from the marital estate prior to its distribution, requiring a reverse and remand of this issue. ¶2 After six days of trial regarding a dissolution petition, the trial court ordered the division of the marital and nonmarital estates, awarding Jill Fritschle what the trial court found to be her nonmarital bank accounts. It further ordered George Fritschle to pay maintenance to Jill, and that Jill’s attorney fees be paid from the marital estate before its division, as outlined in its judgment. 1 For the following reasons, we affirm the trial court’s division of assets and debts, its determination of marital and nonmarital assets, and the award of maintenance. We reverse and remand with directions on its determination regarding the payment of Jill’s attorney fees. ¶3 I. BACKGROUND ¶4 Given that the arguments on appeal are confined to specific issues, only those filings and testimonies at trial relevant to the issues on appeal will be presented here. On November 20, 2023, George filed a petition for the dissolution of marriage against Jill. At the time of filing, he was 59 years old, and she was 68 years old, and they resided in Olney, Illinois. They were married on May 27, 2006, and no children were born of the union. The bench trial lasted six days, beginning on November 25, 2024, and ending on March 3, 2025. ¶5 A. Pretrial ¶6 On November 22, 2024, George filed a motion in limine. Concerning this appeal, count IV sought to prevent Jill from introducing documentation or testimony regarding her First National Bank account number ending in 8809 (FNB 8809), her Raymond James account number ending in 5836 (RJ 5836), and her Raymond James account number ending in W 475 (RJ W475). It was observed that in her response to interrogatory #22 dated January 17, 2024, 1 she identified these accounts as nonmarital; however, she failed to disclose all requested information. It was further argued that during her deposition, Jill stated she could provide documentation to substantiate the nonmarital status of these accounts, but she did not. Therefore, George requested an order prohibiting any testimony or documentation claiming that the three accounts were nonmarital. 1 Jill’s answers to interrogatories were signed and dated January 16, 2024, but the motion states January 17, 2024. 2 ¶7 On the initial day of trial, the trial court addressed several motions prior to the commencement of testimony. Among these was the motion in limine concerning Jill’s nonmarital accounts. George’s oral arguments closely reflected the substance of his written motion. In response, Jill asserted that George had not filed any motion to compel and emphasized that she was examined “in detail” during her deposition. Jill further explained that she attempted to obtain bank records to substantiate her claim that the accounts in question were nonmarital; however, because the bank retains records for only seven years, she could not obtain any canceled checks. Additionally, Jill noted that during George’s deposition, he was specifically questioned under oath regarding whether he claimed any interest in the items Jill identified as nonmarital property, and whether he concurred with her characterization of those accounts. George affirmed that he concurred that the accounts constituted Jill’s nonmarital property. After considering counsel’s arguments, the trial court denied the motion in limine, stating it would not preclude Jill’s testimony or documentation concerning these accounts. The trial court further indicated that it could address any issues pertaining to these accounts during trial, as necessary. ¶8 B. Trial ¶9 The trial extended over a period of six days across several months. ¶ 10 1. George Fritschle ¶ 11 George testified that he resided at 2526 North Shell Road in Olney, and acquired the land for his residence in 1996 when his mother transferred the deed to him. He constructed the residence on that land in August 1996. He and his first wife divorced in May 2005. As a result of that divorce, he was granted exclusive possession over 120 acres, including 5 acres on which the house was situated. On October 26, 2006, he sold 40 acres of the property. The proceeds from this sale, totaling $84,000, were allocated towards the mortgage on the residence, which was paid off in 3 2009. He paid the mortgage with proceeds from the property sale and business dividends. On March 2, 2023, George executed a quitclaim deed transferring the house and five acres to Jill as they attempted to reconcile their marriage. ¶ 12 George is employed by Fritschle Incorporated, a company founded in 1992 and incorporated in the early 2000s. The corporation provided propane to residential clients and agricultural operations. He has maintained a 50% ownership interest in Fritschle Incorporated since 1995. On January 1, 2022, his cousin, Mike, sold his 50% ownership stake to his son, Christopher. ¶ 13 Throughout the year, he received a modest dividend and other supplementary payments. In 2022, he earned an additional $49,200 in rental income from Fritschle Incorporated; however, the average annual amount was $61,367.97. At the time of his marriage, Jill was employed at Stevens Chiropractic and has continued to work there part-time. ¶ 14 George testified about his marital and nonmarital assets and his financial affidavit. He did not include in the financial affidavit the property he asserted was nonmarital. Furthermore, he omitted items valued at over $100,000. From the commencement of the divorce proceedings to the date of trial, George paid more than $100,000 to his attorneys from the Fritschle Farms and Backhoe marital account. ¶ 15 Regarding Jill’s three accounts that were the subject of his motion in limine, he stated that he now considered them to be marital property and was pursuing his equitable share. He claimed they were marital because she initially deposited the funds into a joint account at First National Bank, although he acknowledged that he lacked supporting documentation to substantiate this claim. Furthermore, he could not recall whether he told her that the funds he received from her first marriage were hers and that he would not claim them. He acknowledged that during his 4 deposition concerning these accounts, he had previously agreed that they constituted Jill’s nonmarital property. Following his deposition, he collected certain financial documents to locate specific records. He retained these documents for approximately one week before returning them to the attic. ¶ 16 Regarding the residence, the parties were expected to submit names to conduct an appraisal, and Jill recommended Gary Lewis. He consented to utilize Gary’s services for the appraisal but was unaware that Gary was not a certified appraiser. George regarded Gary’s appraisal as “out of line” and excessively high. He estimated the value of the residence at $370,000, a valuation derived from the appraisal performed by Kay Stinson, whom he engaged. He confirmed that he and Jill initially agreed to engage Gary as the appraiser and had split his fee equally. He expressed dissatisfaction with Gary’s appraised value. ¶ 17 2. Kay Stinson ¶ 18 Kay is a certified general real estate appraiser who appraised the property located at 2526 North Shell Road in Olney on April 26, 2024. She personally conducted a walkthrough of the property and stated that an appraiser must physically observe the property being appraised. She ascertained that the median home value in Olney was $90,000. With a reasonable degree of certainty, as an appraiser, she established the property’s fair market value at $370,000. ¶ 19 She was also requested to review an appraisal conducted by Gary Lewis and prepared a report expressing her opinion regarding his appraisal. Gary was licensed as a trainee, had not attained full certification as an appraiser in Illinois, and was mandated to operate under a supervisory appraiser as a trainee. ¶ 20 To become a fully licensed appraiser, a trainee must complete the requisite coursework and accumulate the required hours in appraisal under the supervision of their designated supervising 5 appraiser before they are eligible to sit for the state examination. Upon successful passing of the examination, the appraiser is authorized to work independently. It was her ordinary business practice to personally inspect all properties on which she provided certification as a licensed appraiser. Regarding Gary’s appraisal, Gary served as the appraiser, and Larry Lewis acted as the supervising appraiser. According to the appraisal report, Larry did not physically inspect the property as of the inspection date, March 16, 2024. ¶ 21 Gary used a financial lender form to complete his appraisal, a document typically used for financial institutions for Fannie Mae and Freddie Mac loans. The form Gary used stated that its intended purpose “is for the lender client to evaluate the property that is the subject of this appraisal for a mortgage-financed transaction.” Conversely, Kay opted for the uniform residential appraisal report for her assessment. The distinction between the two forms primarily pertains to the scope of work. Each form has specific requirements regarding property coding, marketing time, and distance. ¶ 22 Gary stated that the predominant home value in Olney was $350,000 and used a comparable sale price for a residence located 29 miles away, whereas she referenced a comparable sale only 5.69 miles away. Gary’s appraisal did not affect her assessed value of $370,000. ¶ 23 During cross-examination, she testified that her initial meeting with George took place in April 2024. She understood that George was dissatisfied with Gary’s $419,000 appraisal. George was the only person present during the appraisal; she spent about one hour and 20 minutes there, with his company throughout the process. ¶ 24 She testified that it was incorrect to assert that there were no regulations or requirements mandating that the supervising appraiser personally visit the property to conduct a visual 6 inspection; however, she did not have the relevant regulation or rule with her. She never employed a trainee appraiser and never communicated with Gary regarding his appraisal. ¶ 25 3. Gary Lewis ¶ 26 Gary is a residential real estate appraiser with an 18-year tenure in the field, having conducted over 2,600 appraisals. He trained under three certified appraisers. His appraisal services primarily served the secondary market, with clients seeking loans. He was informed that approximately one in six of his reports undergo review by state authorities, with no issues arising from these reviews. His appraisals established the fair market value of properties at the time of assessment. He held the status of an associate real estate trainee appraiser. Although he completed the certification course, he did not pass the certification exam; he passed the licensing exam but not the certification exam. He retook the exam unsuccessfully and opted to remain licensed rather than pursue further certification. As a licensed associate real estate trainee appraiser, he worked under the supervision of his twin brother, a certified real estate appraiser. Gary performed the appraisals, which his brother reviewed and signed off on. No rules or regulations required his brother to personally inspect or review the properties. The State conducted periodic reviews of appraisals, and most banks employed an in-house reviewer. To date, none of his appraisals, whether reviewed by the State or on behalf of banks, had been rejected or questioned. He did not recall whether George or Jill contacted him. The appraisal’s effective date was March 14, 2024. Both George and Jill attended the inspection. ¶ 27 Regarding comparables, he was trained to consider them when compiling a report. If the difference exceeded 25% plus or minus of the gross living area (GLA) relative to the subject property, it would not be deemed a suitable comparable. Consequently, he adhered to this limitation. He sought comparables with square footage close to the subject house in neighboring 7 towns. All of his comparables fell within a range of 10 to 25%, demonstrating that he used appropriate comparables. He prepared and completed the appraisal in accordance with the Uniform Standards of Professional Appraisal Practice. Within a reasonable degree of professional certainty, he opined that the property’s fair market value was $419,000. The appraisal form he used was a widely accepted instrument for determining and conveying the estimated value of residential real estate. ¶ 28 Concerning Kay’s report, he expressed concerns regarding her choice of comparable properties. He did not believe, within a reasonable degree of professional certainty, that the appraisal of $370,000 issued by Kay accurately reflected the fair market value of the property. This skepticism was based on the comparables used and discrepancies in square footage. He opined that her appraisal was “way off.” ¶ 29 During cross-examination, he stated that he attempted the certification test twice and did not succeed on either attempt because he received the wrong test each time. Approximately 99% of his appraisals are conducted for bank lending purposes, with 1% or less for individual clients. As a trainee, his appraisals required his brother, Larry, to sign off on the appraisals. Larry did not personally inspect the subject property. ¶ 30 In his completed appraisal, he inadvertently noted that the definition of market value was defined by Freddie Mac and Fannie Mae. That should not have been included. Furthermore, his report inadvertently indicated that its intended purpose was for “lending purposes for a mortgage finance transaction.” He used the wrong form; the appropriate form should have been the general practice form. The $57.93 per square foot figure in his report was an “error on the computer side.” He stated that he did not input that figure and that the correct amount should have been $134.08. 8 ¶ 31 On redirect, he testified that the form he utilized, which he customarily employed for bank appraisals, did not influence the methodology or the manner in which he determined the fair market value. He could have utilized the same data and entered it into a different form without affecting the outcome. During the appraisal process, both George and Jill accompanied him, and they shared his fee equally. He applied the same methodological approach whether appraising for a bank or an individual. ¶ 32 4. Jill Fritschle ¶ 33 Jill was previously married to Daryl Gayer before her marriage with George. Before marrying George, he instructed her to leave Daryl without taking any belongings. George assured Jill he would provide for her, include her name on the house and business, and that she would not need to take on any responsibilities. She believed him because she loved him. However, George did not fulfill these assurances. After their marriage, she discussed with him about including her name on the assets and he responded that he would do so when he had time. Over time, her repeated inquiries grew, and he told her that the more she persisted, the less likely he was to do it. ¶ 34 Before their marriage, George informed Jill that she was not obliged to work if she wished not to do so, a sentiment he reiterated after they were wed. She responded by saying she preferred to work and wanted to contribute. She was employed part-time as a receptionist at Stevens Chiropractic. She initially planned to retire in December 2023; however, after filing for divorce, she informed her employer that she would delay her retirement. Her preferred retirement date was now projected for May or June 2025. During her days off, she meticulously maintained the residence, performing chores such as laundry and lawn care. She also cultivated the garden and cared for the plants. Her household duties allowed George to focus fully on operating the business. 9 ¶ 35 George told Jill she could retire; however, she chose not to because she was uncertain about her future. She remarked that she “could see some trouble brewing.” In December 2022, George expressed his desire for a divorce and presented her with a document to sign, warning that if she refused, “his lawyer was going to have my ass thrown out of the house.” She declined to sign the papers, and in January 2023, she filed a petition for dissolution of marriage. Five days after she filed her petition, George told her he no longer wanted a divorce. He professed his love for her and implored her to withdraw the divorce petition, promising to include her name on the house deed if she complied. During this period, she was contemplating her options and was being diagnosed with Graves’ disease, a thyroid disorder that induces severe anxiety, impairs voice, and causes hand tremors. Jill took medication for this condition. George assured her that he understood the implications of the disease and pledged to support her through her treatment. Believing his assurances, she withdrew her petition. The couple reconciled and their relationship remained stable until approximately June or July, when tensions resumed. George expressed his inability to cope with her anxiety and Graves’ disease, claiming he had given her four months to recover from the illness, which she did not do, leading him to seek a divorce. Subsequently, in November, she was served with divorce papers, and an officer told her she was “getting evicted from the house,” requiring her to leave immediately. She lived with family members until her lawyer filed a motion to vacate, which allowed her to return to her residence; however, she could not enter the property because George had changed the locks. ¶ 36 In addition to her February 2023 Graves’ disease diagnosis, Jill had an unsuccessful knee replacement surgery in 2022. She was further advised to undergo additional surgical intervention. She also suffered from anxiety and depression, for which she attended therapy and was prescribed medication. 10 ¶ 37 Regarding her financial affidavit, Jill’s monthly living expenses were what she expected them to be when establishing her own residence and maintaining her accustomed lifestyle. She intended to purchase a new vehicle, as her current vehicle was a 2011 Ford, which constituted her nonmarital property and she intended to acquire a residence at least comparable to her dwelling with George. ¶ 38 She randomly selected Gary from a list of approximately five names she had compiled to conduct an appraisal and simply called Gary to inquire whether he knew her or George; he did not. George consented to utilizing Gary. Both parties were present when Gary examined the house, and they agreed to share the payment equally. After receiving the appraisal, George refused to accept it because it did not align with his expectations. George contacted Kay. Jill was not present when Kay arrived because George did not inform her of Kay’s arrival time. ¶ 39 She discussed her marital settlement agreement from her first husband which detailed the payments he was obligated to make to her, $150,000, payable in 10 annual installments of $15,000 each, beginning May 1, 2002. Copies of these checks were admitted as an exhibit, which George objected to on the grounds that they were produced after the close of discovery and had been the subject of a prior motion in limine. The parties discussed the prior motion in limine and the denial of a motion to reopen discovery. The trial court stated: “But from sitting through this trial, this being Day 5, I believe, the testimony was that Mr. Fritschle was not going to claim that as—or was going—not disputing that being her nonmarital property. And then it came out when he was testifying that, yes, he did. And we had extensive discussion about the depositions and what was stated during the depositions. And the fact that these were offered two weeks after the fact, still with plenty of time to cross-examine and present additional evidence, I don’t think that there’s any 11  surprise to anybody that these were going to come in after the fact. I don’t think there was any bad faith on anybody’s part of trying to hide them or claim or not claim this being marital or nonmarital. And so for those reasons, that’s why I denied the motion, and that’s why I will deny the objection or overrule the objection, excuse me.” ¶ 40 Jill clarified that she deposited these funds into multiple accounts solely in her name to prevent anyone else from accessing them. She had told George this, and he responded that such arrangements were acceptable and assured her he would not attempt to access the accounts. The accounts holding these funds were always in her name alone. Furthermore, even if she transferred or rolled over these funds into other accounts, the new accounts also bore only her name; she consistently ensured this. ¶ 41 The day following her deposition, Jill went to the residence’s attic, where they stored their tubs containing financial documents. All six tubs were missing. She asked George about their whereabouts, and he said he had them and that she could have them once he finished with them. One week later, the boxes were returned to the attic, and upon inspection, she found they had been rummaged through, and all her account documents had been removed. She also tried to obtain records from 2006 onward by contacting the banks. First National Bank told her it could provide records only going back seven years, and Citizens National Bank said it could not retrieve the records without an account number. ¶ 42 She testified about an exhibit regarding a First National Bank account opened on May 15, 2008, in her name only, funded with money from her settlement with her previous husband. With that money, in 2013 she bought a $75,000 CD at Citizens National Bank, which she closed in 2018 and received a check for $80,022.93. She deposited that money into First National Bank on June 12 20, 2018, and then opened a Raymond James account (RJ W475) with $80,000 of it on June 21, 2018. As of June 28, 2024, it held a balance of $88,740.13. ¶ 43 She testified about exhibits showing the First National Bank money market account ending in 8809 (FNB 8809), which held a balance of $44,642 and originated from funds received from her first marriage; George had not been on this account. ¶ 44 The Roth IRA Raymond James account number 5836 (RJ 5836) contained $22,490, sourced from her first marriage, and as of June 28, 2024, had a balance of $21,961.62. Her life insurance policy with Country Life Insurance had a value of $10,160 and was established premaritally. She requested the full distribution of all her nonmarital property. ¶ 45 A judgment of dissolution of marriage was entered on July 25, 2025. Relevant to this appeal, the trial court determined that the appraisals conducted by both Gary and Kay were “consistent with the valuation practice standards” and accorded equal weight to both of their opinions and established the value of the marital residence at $394,500. ¶ 46 With respect to FNB 8809, the trial court acknowledged the parties’ disagreement over whether it should be classified as nonmarital property, but both parties valued the account at $44,642. The trial court found Jill to be credible regarding “where the funds came from and where the funds were transferred.” It noted that George’s “testimony conflicted between his discovery deposition and at trial as to whether or not these funds were Jill’s non-marital property.” The trial court concluded that Jill met her burden of proof that the funds were nonmarital and assigned them a value of $44,642. The trial court applied the same analysis to RJ 5836, which it valued at $22,490 as Jill’s nonmarital property. Additionally, the trial court deemed RJ W475 Jill’s nonmarital property, valued at $88,740. 13 ¶ 47 Regarding maintenance, the trial court noted that Jill requested a monthly amount of $1,591 until her retirement, thereafter increasing to $2,493 per month. George objected to her maintenance request. The trial court stated that, in evaluating the appropriateness of maintenance, it “expressly considered the testimony presented, duly admitted exhibits, and other relevant evidence related to the statutory factors outlined in 750 ILCS 5/504.” It then listed the statutory factors and analyzed the relevant facts against them. After reviewing the statutory considerations, the trial court concluded that maintenance was warranted. To determine the appropriate amount, the court employed George’s annual salary of $60,000, the average of his last three years of “rent/dividend” payments, and the average income from farming and backhoe operations over the same period, resulting in an annual income of $126,600 for George. For Jill, the trial court used her current income and Social Security benefits to establish her income at $38,000. Based on these figures, the trial court calculated a monthly maintenance amount of $1,322.42, payable for 11 years and 3 months. The trial court also specified that upon Jill’s retirement, both parties should submit proposed maintenance calculations. If the parties could not agree on an amount, the trial court would recalculate maintenance based on the submitted information. ¶ 48 Regarding the contribution of attorney fees, the trial court stated that George had paid $110,000 in attorney fees as of the January 2025 trial date, and anticipated that he had paid considerably more since then. It noted that most, if not all, of the attorney fees were from the Fritschle Farms and Backhoe account, which was classified as a marital asset. Jill contributed $15,000 towards her attorney fees, leaving an outstanding balance of $56,691.81. The trial court observed that the parties possessed substantial marital assets, “including various cash accounts from which to pay Jill’s attorney’s fees.” It further noted that George’s attorney fees exceeded Jill’s by more than double, which the trial court deemed excessive. The trial court stated that it 14 considered the statutory factors and ordered that $56,691.81 be paid from the parties’ marital estate to Jill’s attorney before the division of the marital assets. ¶ 49 With respect to the division of the marital estate, the trial court articulated that it considered all of the equitable distribution factors enumerated in section 503(d) of the Illinois Marriage and Dissolution of Marriage Act (Act) (750 ILCS 5/503(d) (West 2022)) and indicated that “[d]ue to the significant disparity of non-marital property, the Court does not find that an equal distribution of the marital estate is appropriate.” The trial court allocated the cash and investments, automobiles and personal property, and life insurance so that George’s net value amounted to $800,607 and Jill’s to $1,736,170. ¶ 50 C. Posttrial ¶ 51 The parties filed several posttrial motions. George’s August 22, 2025, motion to reconsider contended that the trial court did not consider “the income or income producing capacity of the cash or cash equivalent amounts awarded” to Jill in determining whether maintenance was even appropriate, and thereby erred in its maintenance award. He also asserted that there was no “competent evidence” as to Jill’s reasonable needs to maintain her standard of living. He also argued that Jill failed to rebut the presumption that her bank and investment accounts were marital property. He asserted that no documentary evidence established that the funds in her accounts originated from a nonmarital source. He objected to the trial court’s valuation of the marital residence and its use of Gary’s appraisal since he was not a “qualified, certified real estate appraiser.” George contested the trial court’s distribution of property, arguing that the trial court did not consider George’s contribution to acquisition of the marital estate. He argued that he was entitled to “a majority of the marital estate because of his contribution.” On August 25, 2025, Jill 15 filed a posttrial motion, arguing that her payment of attorney fees should not come from the marital estate and that it should be paid by George. ¶ 52 A hearing was conducted on October 17, 2025, and the trial court issued a written ruling on October 29, 2025. Regarding the motion to reconsider maintenance, the trial court denied that part of the motion. It stated that it considered all factors contained in section 504 of the Act, which it set forth in the judgment of dissolution of marriage (750 ILCS 5/504 (West 2022)). It stated that it “clearly considered” the factors with which George had an issue and even pointed out the paragraphs within its judgment where it discussed those contentions. The trial court indicated that it disagreed with the statement that there was no evidence of Jill’s needs, as it found Jill’s financial affidavit “served as an estimate as to what her living expenses would be once the parties no longer lived in the same residence.” The trial court stated that her needs were “clearly established through” Jill’s testimony and portions of the discovery deposition that George admitted into evidence. ¶ 53 The trial court denied George’s motion to reconsider property classification. The trial court indicated that it found Jill to be a credible witness and that she traced the funds she received from her first husband through documentation she obtained from the bank or other financial institutions. It found that Jill met her burden by showing by clear and convincing evidence that the accounts constituted her nonmarital property. ¶ 54 The trial court denied George’s motion to reconsider regarding the value of the marital home. It disagreed with George’s assessment that it erred in considering Gary’s appraisal. It found that Gary had years of experience and had prepared thousands of appraisals, and was hired by both parties. Kay was hired only by George, paid by him, accompanied him, and knew his concerns 16 about Gary’s appraisal. The trial court found “both valuations consistent with valuation practice standards and therefore gave equal weight to both appraisals.” ¶ 55 As to George’s motion to reconsider the distribution of property, the trial court denied it. It stated that it clearly considered all of the equitable factors set forth in section 503(d) and that “because the Judgment of Dissolution of Marriage did not specifically set forth each factor, it should not be implied that the Court did not consider the factors.” The trial court disagreed with George’s assessment that Jill contributed nothing to the acquisition of the marital estate. ¶ 56 The trial court denied Jill’s motion to reconsider contribution of attorney fees. The trial court indicated that it considered the statutory factors “including the significant amount of marital and non-marital property awarded” to the parties, as well as the financial resources of both parties, including the awarding of maintenance. George filed a notice of appeal on November 19, 2025. ¶ 57 II. ANALYSIS ¶ 58 On appeal, George raises four issues: (1) the trial court’s award of maintenance was in error because it did not consider the financial impact of the marital property awarded to Jill and because it did not evaluate whether the award was necessary to meet Jill’s reasonable needs; (2) the trial court erred in classifying certain accounts held by Jill as nonmarital property, George asserting that Jill failed to overcome, by clear and convincing evidence, the presumption that the accounts were marital; (3) the trial court erred in assigning equal weight to both appraisals; and (4) the trial court erred in its distribution of property by failing to consider George’s contribution to the marital estate during the apportionment. Jill cross-appeals, arguing that the trial court erred by ordering her attorney fees to be paid from the marital estate rather than requiring George to bear sole responsibility for them. Each issue is addressed in turn. 17 ¶ 59 A. Maintenance ¶ 60 George contends that the trial court failed to evaluate two of the factors specified in section 504(a) of the Act, specifically subsection (a)(1), which pertains to the consideration of marital and nonmarital property assigned, and subsection (a)(2), which concerns Jill’s reasonable needs. In setting an award of maintenance, the trial court must first consider the 14 factors outlined in section 504(a) of the Act. 750 ILCS 5/504(a)(1)-(14) (West 2022). In considering these factors, the circuit court is not required to give them equal weight “ ‘so long as the balance struck by the court is reasonable under the circumstances.’ ” In re Marriage of Bradley, 2011 IL App (4th) 110392, ¶ 36 (quoting In re Marriage of Miller, 231 Ill. App. 3d 480, 485 (1992)). “No single factor is determinative when considering the duration and amount of a maintenance award.” In re Marriage of Heroy, 385 Ill. App. 3d 640, 651 (2008). Additionally, although the circuit court must consider all the relevant statutory factors, it need not make specific findings as to the reasons for its decisions. Bradley, 2011 IL App (4th) 110392, ¶ 36. “ ‘The benchmark for determining the amount of maintenance is the recipient’s reasonable needs in light of the standard of living established during the marriage.’ ” Id. (quoting In re Marriage of Culp, 341 Ill. App. 3d 390, 398 (2003)). A maintenance order will not be reversed on appeal unless the record shows an abuse of discretion. In re Marriage of Breuer, 259 Ill. App. 3d 94, 96 (1994). “A reversal is justified only when it is obvious that the trial court acted arbitrarily or without conscientious judgment.” In re Marriage of Schrimpf, 293 Ill. App. 3d 246, 252 (1997). ¶ 61 In its order awarding Jill maintenance, the trial court articulated its findings in the judgment on each statutory subsection under section 504 of the Act, even though such a detailed analysis was not required. It enumerated each factor and then examined the evidence and testimony pertinent to each, including the two subsections George contests. Subsequently, in its order 18 denying George’s motion to reconsider the trial court reaffirmed that it had considered all relevant factors. ¶ 62 Regarding the initial subsection, the trial court, in its original judgment, addressed several financial considerations, including that both parties were awarded substantial property in the allocation of marital assets, and that George possesses significant nonmarital property which generates income, while Jill also has nonmarital property, albeit of lesser significance than George’s. Subsequently, in response to George’s assertion that the trial court did not consider this subsection, and more specifically, the income-producing capabilities of the assets, it stated that “[a]lthough counsel for [George] argued that the Court did not take into consideration the allocation of marital and non-marital property, along with the income or potential earning capacity of said property, this Court clearly considered these factors” (emphasis added). In fact, the trial court identified specific pages and paragraphs of the original judgment where it examined and analyzed this factor. George’s assertion that the trial court did not consider this subsection is clearly rebutted by the record. ¶ 63 In any e