In re Marriage of Arjmand, 238 N.E.3d 1067

The case arises from a lengthy marriage dissolution proceeding between Masud M. Arjmand (petitioner) and Muneeza R. Arjmand (respondent), ongoing since 2009.
Initial dissolution order (2009) was partially vacated in 2012 after allegations of coercion and fraud regarding the marital settlement agreement; only the dissolution stood.
Related litigation includes orders restricting asset transfers, repeated appeals, collateral claims by petitioner against third parties (including Morgan Stanley and attorneys), and repeated attempts for judicial substitution.
Petitioner’s attempts for substitution of judge were denied; later, his complaint against Morgan Stanley and attorneys was dismissed with prejudice, which he appealed under Illinois Supreme Court Rule 304(a).
The appellate court affirmed the trial court's dismissal of some claims, but declined jurisdiction to review the denial of petitioner’s petitions for substitution of judge, prompting this appeal to the Illinois Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Rule 304(a) allow appellate jurisdiction to review denials of substitution of judge?	Yes; such orders should be reviewable as they impact the fairness of proceedings.	No; Rule 304(a) only covers certain final/interlocutory orders.	No; Rule 304(a) does not confer jurisdiction over those orders.
Can prior orders (like substitution denials) be reviewed if involved in procedural sequence?	Yes. Related orders should be appealable if in procedural chain.	No; only those intertwined with the merits of the appealable order.	No; only orders affecting the merits qualify, not these procedural ones.
Should judicial economy factor into expanding appellate jurisdiction in this context?	Yes; helps avoid unnecessary litigation delays.	No; jurisdiction rules cannot be bypassed for efficiency.	No; judicial economy does not override Supreme Court rules.
Are earlier cases (e.g., Berlin) from other districts binding or persuasive here?	Yes; they support jurisdiction where fairness is at issue.	No; not binding, and other district cases hold otherwise.	No; follows Second/Third Districts rejecting those precedents.

In re Marriage of Lentz, 79 Ill. 2d 400 (Ill. 1980) (explains Rule 304(a) policy of avoiding piecemeal appeals)
Towns v. Yellow Cab Co., 73 Ill. 2d 113 (Ill. 1978) (discusses finality of judgments for appeal)
Burtell v. First Charter Serv. Corp., 76 Ill. 2d 427 (Ill. 1979) (holds non-listed procedural orders may be reviewed if in procedural chain to final judgment)
Ariola v. Nigro, 13 Ill. 2d 200 (Ill. 1958) (explains rationale for limiting interlocutory appeals)
General Motors Corp. v. Pappas, 242 Ill. 2d 163 (Ill. 2011) (addresses limits of notice of appeal for appellate jurisdiction)