Konfrst v. Steklik, 2014 IL App (1st) 132113

Decedent (Beverly Czerwinski) opened a checking and a money market account at Charter One in ~2003; defendant (niece Cynthia Stehlik) was later added to both accounts and did not contribute funds.
Decedent paid living expenses from the accounts; balances stayed high (never below ~$80,000). Defendant performed limited transactions (≈10–15 checks) and handled statements late in decedent’s life.
After decedent’s death in 2010, defendant withdrew the full balances: ~$255,235.57 from the money market account and ~$8,836.36 from the checking account.
Executor (Konfrst) sued under a citation to recover account funds, arguing the accounts were not valid joint tenancies under the Illinois Joint Tenancy Act and/or were convenience accounts.
Trial court found the checking account was a convenience account (funds to estate) but held the money market account was a valid joint tenancy with right of survivorship (funds to defendant). Plaintiff appealed only the money market ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the money market account complied with the Joint Tenancy Act	Stehlik failed to produce the signed written agreement; thus no valid joint tenancy	Bank records, account forms, signatures, statements, and surrounding facts corroborate a signed survivorship agreement	Court: Defendant met clear-and-convincing burden; account complied with Act
Whether the account was a "convenience account" (no donative intent)	Decedent intended defendant to have only a future interest; account used to pay bills; neighbor/tenant relationship shows convenience use	Decedent expressed intent that account would belong to defendant at death; creating other joint accounts for siblings shows testamentary plan	Court: Plaintiff failed to rebut presumption of a present donative gift; not a convenience account

Doubler v. Doubler, 412 Ill. 597 (1952) (Act requires a signed written agreement to create bank-account joint tenancy)
In re Estate of Regelbrugge, 225 Ill. App. 3d 593 (1992) (signed agreement may be proven by corroborating evidence; factors to consider surrounding account creation/use)
Murgic v. Granite City Trust & Savings Bank, 31 Ill. 2d 587 (1964) (statutory joint-account agreement creates presumption of present gift)
Harms v. Sprague, 105 Ill. 2d 215 (1984) (donor intent to create survivorship interest is the essence of joint tenancy; testamentary use is consistent with survivorship)
Frey v. Wubbena, 26 Ill. 2d 62 (1962) (intention to create survivorship arrangement governs analysis)
Johnson v. La Grange State Bank, 73 Ill. 2d 342 (1978) (joint account agreement can indicate an inter vivos gift despite directions limiting use during life)
In re Estate of Shea, 364 Ill. App. 3d 963 (2006) (convenience-account analysis; clear-and-convincing standard to rebut presumption)