In re Marriage of Susman, 980 N.E.2d 131

Dissolution judgment filed Oct 30, 2009 incorporated a marital settlement agreement (MSA) allocating estate (~$15M) and reserving issues on pre-2008 taxes and on personal property.
MSA stated tax issues and property division to be determined later by court or agreement.
Arthur filed Mar 30, 2010 a motion to modify the judgment alleging mutual mistake of fact regarding 2009 tax liabilities from a $2.7M legal fee.
June 6, 2011 hearing denied the motion to modify; personal property issues remained unresolved.
Arthur filed a motion to reconsider on Jun 21, 2011; denied Jun 28, 2011; he appealed the denial.
Court dismissed the appeal for lack of jurisdiction because the dissolution judgment was not final and thus the order denying modification was not a final, appealable judgment, due to reserved ancillary issues under a bifurcated judgment under 750 ILCS 5/401(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the dissolution judgment was final and appealable given reserved issues	Susman argues finality; the order resolves modification issues	Judgment not final; ancillary issues reserved	No final judgment; appeal dismissed for lack of jurisdiction

In re Marriage of Leopando, 96 Ill. 2d 114 (1983) (dissolution judgments not final until ancillary issues resolved)
In re Marriage of Mackin, 391 Ill. App. 3d 518 (2009) (final judgment rule; dissolution orders not final when issues remain)
In re Marriage of Mardjetko, 369 Ill. App. 3d 934 (2007) (sua sponte jurisdiction review for appealability; finality requirement)
In re Marriage of Capitani, 368 Ill. App. 3d 486 (2006) (ancillary issues reserved; general finality rule applies)
In re Marriage of Kenik, 181 Ill. App. 3d 266 (1989) (bifurcated judgments; review constraints)
In re Marriage of Thomas, 213 Ill. App. 3d 1073 (1991) (lack of finality where dissolution issues unresolved)