The parties had been married in Iowa. They lived together until wife moved to Illinois. Wife filed a Petition for Dissolution of Marriage in Illinois.

Summons was issued to husband.  He was then a resident of the state of Georgia.   He was personally served.

The petition for dissolution requested that the court award wife a divorce, her nonmarital property, her equitable share of the marital property, and other relief as the court deemed equitable.

Husband did nothing after being served.

Wife sent notice to husband that the case was set for a default hearing on the petition for dissolution of marriage. Husband did not appear for the hearing.   An order of default was entered.

The court heard testimony from wife.  It granted the petition for dissolution.  It also ruled on the division of various assets and liabilities.

Over $65,000 in liabilities was given to husband.   He was to hold wife harmless. The court also entered judgment against husband for $22,500.  This was for property that wife  had contributed to start husband’s business.

Wife later filed a citation notice.   She sought collection of the $22,500 judgment.  Husband, through his attorney, filed a general appearance.

Two months later, husband filed a motion to dismiss the citation.   On the grounds that the court lacked personal jurisdiction.  He argued that Illinois was not the matrimonial domicile.  And he argued that he had not submitted to jurisdiction in Illinois.

Two days later, husband filed a special and limited appearance.   He attacked jurisdiction on the underlying judgment. He agreed that the judgment dissolving the marriage was proper.  However, he moved to vacate the judgment as it related to property.

The court heard arguments.  It entered an order striking husband’s special and limited appearance, finding that the general appearance subjected husband to personal jurisdiction and retroactively applied to the prior judgment of dissolution. Husband moved for reconsideration of the order.   This was denied.   Husband appealed.

The postjudgment general appearance did not subject husband to personal jurisdiction retroactively.  Further, it did not serve to validate the previous judgment entered.

IRMO Hoover, 314 Ill.App.3d 707