Justin Dalcollo was convicted by a jury of six counts of aggravated criminal sexual assault, aggravated kidnapping, armed robbery, and two counts of unlawful use of a weapon by a felon, receiving an aggregate 101-year sentence. After his convictions were affirmed on direct appeal, he filed a postconviction petition arguing that his due process rights were violated when the State proceeded to trial on previously nol-prossed charges without formally reinstating them, and that appellate counsel was ineffective for failing to raise this claim. The Du Page County circuit court summarily dismissed the petition at the first stage as frivolous and patently without merit, and Dalcollo appealed.

The Third District affirmed. The court held that Dalcollo's due process claim — premised on the right to notice of charges — was flatly rebutted by the trial record. Within days of the court granting his motion to withdraw his guilty plea, Dalcollo filed motions acknowledging all 14 counts were pending. The State expressly stated at a June 2021 hearing that trial was set on all counts, and Dalcollo confirmed his understanding two weeks before his December 2021 trial. With at least seven months of actual notice, no surprise, unfairness, or impaired defense preparation was shown. Because the underlying due process claim lacked merit, appellate counsel could not have been ineffective for omitting it.

The court also expressed doubt that People v. Hughes and People v. Shinaul prescribe the exclusive procedures for recommencing prosecution on nol-prossed charges, noting that a blanket prohibition would conflict with a trial court's inherent authority to vacate its own orders. Additionally, Illinois Supreme Court Rule 605(c)(4)'s admonishment requirement was inapplicable because no sentence had been imposed before Dalcollo moved to withdraw his plea.

This opinion from Rule 23 was filed on 2026-07-08. The case "Kessem v. Chicago Teachers Union, 2026 IL App (1st) 251006" (Docket: 2026 IL App (1st) 251006) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.

Plaintiff Olivia Aguilar filed a negligence action on March 10, 2025 in Cook County Circuit Court against Schindler Elevator Corporation and an employee, alleging she suffered a left shoulder injury on January 22, 2023 when an elevator door struck her. Defendants moved to dismiss under section 2-619(a)(5), arguing the action was time-barred under Illinois's two-year personal injury statute of limitations. The trial court granted the motion and dismissed the first amended complaint with prejudice. Plaintiff appealed, arguing the discovery rule should toll the limitations period because her preexisting chronic cervical spine condition masked her awareness of a distinct, actionable shoulder injury.

The Illinois Appellate Court, First District, affirmed. Applying de novo review, the court held that the sudden, traumatic event rule precluded application of the discovery rule. Because the elevator door unexpectedly struck plaintiff's shoulder and caused her immediate pain, the law presumes she was placed on notice of a potential injury and right of action on the date of the incident. Plaintiff's subjective belief that her pain stemmed from a preexisting condition did not negate her objective knowledge that the door caused immediate pain, which triggered her duty to inquire further.

This decision is significant for personal injury and defense counsel because it reinforces that a plaintiff's preexisting condition will not automatically invoke the discovery rule where a sudden, external traumatic event causes immediate, perceptible pain. Attorneys should counsel clients promptly following any traumatic incident, regardless of diagnostic uncertainty.

Jerrold Rapcan was convicted after a jury trial in Kendall County of two counts of criminal sexual assault and two counts of sexual relations within families. The trial court imposed consecutive five-year terms on the assault counts and, after a motion to reconsider, vacated the family-relations convictions under the one-act, one-crime doctrine. On appeal, Rapcan argued the State failed to prove he used force or the threat of force as required under 720 ILCS 5/11-1.20(a)(1).

The Second District reversed the criminal sexual assault convictions, holding the evidence was insufficient. The State conceded no actual physical force beyond that inherent in penetration was used, so the court focused on threat of force. It found that the victim's subjective fear—rooted in Rapcan's physical size, fitness, and prior property destruction—did not constitute an actual threat, as Rapcan never struck the victim or made verbal or specific physical threats during the encounters. Relying on People v. Lamonica and People v. Mpulamasaka, the court reaffirmed that a victim's generalized apprehension of a defendant's demeanor cannot substitute for proof of an actual threat.

With the assault convictions reversed, the predicate for merger dissolved, and the court reinstated the sexual relations within families convictions with the original three-year sentences, resolving an oral/written sentencing discrepancy in favor of the oral pronouncement. The court remanded solely for the trial court to determine whether discretionary consecutive sentencing is warranted for protection of the public under 730 ILCS 5/5-8-4(c)(1), a question the trial court never reached because mandatory consecutive sentencing had previously applied.

This opinion from Rule 23 was filed on 2026-07-07. The case "People v. Ware, 2026 IL App (4th) 250443" (Docket: 2026 IL App (4th) 250443) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.

In Hendrick v. Hendrick, the Illinois Fifth District Appellate Court reversed the Champaign County circuit court's dismissal of count I of plaintiffs' third amended complaint, which alleged that co-trustee Bobbie Hendrick breached her fiduciary duties in administering two family trusts whose primary asset was Hendrick House, a family-owned corporation. Betsy Hendrick and Rebecca Rowe alleged that Bobbie orchestrated the installation of her husband Terrell Williams as president of Hendrick House, diverted trust resources to benefit her own household, packed the board with her children, excluded other beneficiaries from management, and allowed the corporation to operate at a loss for years while Bobbie, Terrell, and their children received compensation funded by borrowed money.

The appellate court held that all four alleged breaches — loyalty, impartiality, prudent administration, and good faith — were sufficiently pleaded to survive a section 2-615 motion to dismiss. On loyalty, the court applied the statutory presumption of conflict under section 802(b)(1) of the Illinois Trust Code, which arises when a trustee manages trust property through a transaction involving the trustee's spouse, placing the burden on Bobbie to rebut the presumption with clear and convincing evidence. On impartiality and prudent administration, the court found specific factual allegations regarding operational losses, failure to scrutinize Terrell's financial reports, and unequal distributions sufficient to preclude dismissal.

For trust litigators, this decision reinforces that Illinois's fact-pleading standard does not require exhaustive evidentiary detail at the pleading stage, and that the section 802(b)(1) spousal conflict presumption is a powerful tool for plaintiffs challenging trustee self-dealing involving a spouse placed in a management role over trust assets.

Ernesto Valle was convicted of first degree murder and sentenced to a mandatory 45-year term (20 years plus a consecutive 25-year firearm enhancement). After his conviction, direct appeal, and initial postconviction petition were all affirmed, Valle sought leave in 2019 to file a successive postconviction petition raising two claims: (1) an as-applied proportionate penalties challenge to his mandatory de facto life sentence based on his youth at the time of the offense, and (2) a claim that his confession was coerced and his Miranda waiver involuntary. The Kane County Circuit Court granted leave and advanced the petition to the second stage, but ultimately dismissed it. The Second District affirmed.

On the sentencing claim, the court held that Miller v. Alabama—which applies only to juvenile offenders—did not change the law applicable to young adult offenders (ages 18–20) and therefore cannot establish cause for raising a proportionate penalties claim in a successive petition, regardless of whether the sentence was mandatory or discretionary. The court further found that Illinois courts have long recognized youth as a sentencing consideration, meaning defendant possessed the essential legal tools to raise this claim in his initial petition. On the confession claim, the court found it barred by res judicata, having been litigated on direct appeal and in federal habeas proceedings, and rejected defendant's attempt to establish cause through a 2018 Reid Method critique and an expert report that expressly disclaimed ability to verify the coercion allegation.

This decision is significant for criminal defense attorneys handling successive postconviction petitions: it reinforces that Miller-based cause arguments are unavailable to young adult offenders and that expert reports offering only speculative or qualified support for previously litigated claims will not satisfy the cause-and-prejudice standard.

Dr. William Sullivan, an emergency physician, sued Allison Schiman, Rodney Perez, and Ally Anderson LLC for defamation per se, false light, and intentional infliction of emotional distress arising from a Facebook post falsely accusing Sullivan of sexually assaulting a patient during a medical examination, which Perez reposted and featured. Following a four-day bench trial in La Salle County, the circuit court found both Schiman and Perez liable for defamation per se and found that Sullivan suffered actual mental anguish—including sleep loss, embarrassment, and changes in patient care behavior—yet awarded only $1 in nominal damages against each defendant. The court also denied Sullivan's post-trial motion for sanctions under Illinois Supreme Court Rules 219(b) and 137 based on Perez's false responses to requests to admit.

The appellate court reversed on both issues. On damages, the court held that nominal damages are appropriate only when no actual, meaningful harm occurred. Because the trial court affirmatively found actual mental anguish, and because damages are presumed in defamation per se cases, the $1 award was legally inconsistent with those findings. The court vacated the nominal damages award and remanded for entry of a proper compensatory damages award, emphasizing that difficulty in calculating reputational harm does not render the injury uncompensable. On sanctions, the court held that the trial court abused its discretion by denying the Rule 219(b) motion without applying the rule's required three-part criteria—instead citing the 'stage of the game' and the breadth of Perez's deposition, neither of which are proper considerations under the rule.

For practicing attorneys, this decision reinforces that a finding of actual harm in a defamation per se case forecloses a nominal damages award, and that trial courts must rigorously apply Rule 219(b)'s enumerated criteria when ruling on sanctions motions for false denials of requests to admit.

This opinion from Rule 23 was filed on 2026-07-07. The case "Real Estate Naperville II, LLC v. E&S Management Group, LLC, 2026 IL App (3d) 250183" (Docket: 2026 IL App (3d) 250183) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.

In December 2022, Chadrick Deon Miller was charged in Union County with burglary, criminal damage to property, vehicle theft conspiracy, and two counts of felony theft arising from an incident at Rusty's Home Center in Anna, Illinois. Miller filed a motion for discovery sanctions alleging multiple violations by the State, including delayed production of recorded interviews of Miller and codefendant Pratis, failure to preserve complete surveillance footage from Rusty's, loss of a park surveillance video, and failure to preserve a Gatorade bottle intended for DNA testing. The circuit court granted the motion and dismissed all charges with prejudice. The State appealed.

The Fifth District reversed on the due process and sanctions issues while affirming that discovery violations occurred. On due process, the court applied Arizona v. Youngblood and found no bad faith—law enforcement's failures stemmed from a miscommunication between officers about evidence collection responsibilities, not intentional misconduct. Because the evidence was only potentially useful rather than materially exculpatory, the absence of bad faith was fatal to the due process claim. On sanctions, the court held that dismissal was disproportionate: the State's witness Pratis could testify live, defense counsel acknowledged the videos likely contained no exculpatory evidence, and the interview videos were eventually produced. The court remanded for the circuit court to impose more moderate, proportionate sanctions.

This case is significant for Illinois criminal practitioners because it clarifies that dismissal under Rule 415(g)(i) is a last resort requiring proportionality analysis, and that negligent—rather than bad faith—evidence loss does not support dismissal on due process grounds.

LDR Cleaning & Restoration, Inc. sued Felicia Johnson for breach of contract arising from an unpaid water damage restoration project. After defendant's original counsel failed to respond to requests for admission and missed hearings, a default judgment was entered but later vacated when defendant appeared pro se. New counsel entered an appearance, but plaintiff ultimately obtained summary judgment for $56,317.50 based on the verified complaint, the parties' agreement, deemed-admitted requests for admission, and supporting affidavits. Defendant appealed pro se.

On appeal, defendant's opening brief challenged only the vacated default judgment and failed to comply with Illinois Supreme Court Rule 341(h), including by omitting a statement of facts and failing to cite pertinent authority. The court declined to strike the brief given the straightforward record but found all opening brief arguments meritless, as there was no default judgment in existence to contest. Defendant's reply brief raised entirely new arguments — including challenges to the summary judgment on grounds of disputed material facts, insufficient evidentiary support, and attorney abandonment — all of which the court held were forfeited under Rule 341(h)(7) because they were not raised in the opening brief.

Addressing the reply brief arguments in the alternative, the court found each independently meritless. Bare allegations of disputed facts without evidentiary support cannot defeat summary judgment. Defendant's attorney abandonment argument failed because the default judgment had already been vacated, the cited cases were inapplicable, and there is no constitutional right to effective assistance of counsel in civil proceedings.

In People v. Reeves, the Fourth District reversed a Stephenson County trial court's order granting defendant Rahmeir Reeves's motion to suppress evidence obtained during a police-citizen encounter. Officer Anderson parked his squad car behind and to the side of defendant's parked vehicle, illuminated the car with a spotlight and flashlight, and engaged defendant in conversation. Defendant was ultimately arrested after Anderson learned his license was suspended, leading to the discovery of evidence underlying charges of aggravated criminal sexual abuse. The trial court suppressed the evidence, finding a Fourth Amendment seizure had occurred. A parallel federal prosecution resulted in a similar suppression ruling by a federal district court.

On appeal, the central issue was whether Officer Anderson's conduct constituted a seizure requiring legal justification. Applying the Mendenhall factors and relying heavily on People v. Luedemann, the appellate court held no seizure occurred. Anderson was the sole officer, displayed no weapon, made no physical contact, spoke casually, and never activated his emergency lights. Critically, the court found Anderson did not block defendant's vehicle — defendant could have backed out or exited eastbound without impediment. The court held that use of a spotlight and flashlight alone, without blocking, is insufficient to constitute a seizure under an objective reasonable-person standard.

The court also held that the federal district court's contrary suppression ruling was neither binding nor persuasive, as Officer Anderson did not testify in the federal proceeding, leaving that court with an incomplete evidentiary record. Practitioners should note that the blocking of a vehicle remains the critical factual distinction in vehicle-encounter seizure analysis, and that parallel federal suppression rulings do not bind Illinois state courts.

Blake Jennings was convicted after a jury trial in Jackson County of unlawful use of a weapon by a felon (UUWF), aggravated battery, and resisting a peace officer. The UUWF charge was premised solely on Jennings's possession of a knife with a blade over three inches in length, and the aggravated battery charge was elevated based on the allegation that the offense occurred on a public way — specifically, a private roundabout within Brookside Apartments. The trial court imposed a 10-year consecutive sentence for UUWF and a 3-year sentence for aggravated battery. Jennings appealed, challenging the sufficiency of evidence on both enhanced charges.

The Fifth District reversed both convictions. On the UUWF count, the court held that a blade longer than three inches is not among the per se prohibited weapons under 720 ILCS 5/24-1(a)(1), and mere possession of such a knife is not a crime. The State's attempt on appeal to recast the box cutter as a switchblade was rejected under People v. Crespo because that theory was never charged, argued, or submitted to the jury. On the aggravated battery count, the court applied People v. Whitehead, 2023 IL 128051, to hold that the private apartment complex roundabout did not constitute a 'public way,' rejecting pre-Whitehead decisions that had treated privately owned but publicly accessible areas as sufficient. The aggravated battery conviction was reduced to simple battery, and no resentencing was required because Jennings had already served 18 months — exceeding the maximum for a Class A misdemeanor.

This decision is significant for criminal defense practitioners because it clarifies that the State cannot broaden its weapon theory on appeal after confining itself to a legally insufficient theory at trial, and it extends Whitehead's restrictive public-access framework to the 'public way' aggravator in the aggravated battery statute.

Patricia Eads, as trustee of the William H. Dorman Trust, filed a quiet title action in Madison County alleging that a fence erected by defendant Amanda Abernathy in 2021 encroached on Trust property. After a bench trial, the circuit court entered judgment for defendant on December 14, 2023, finding plaintiff failed to meet her burden of proof. The court also found the action was frivolous and not brought in good faith, imposing Rule 137 sanctions sua sponte. The amount of attorney fees ($7,091) was determined at a December 16, 2024 hearing, and plaintiff filed her notice of appeal on January 15, 2025.

On appeal, the Fifth District affirmed on all issues. The court held it had jurisdiction because the December 14, 2023 order was not final while the Rule 137 fee amount remained pending and no Rule 304(a) finding had been entered, making the January 2025 notice of appeal timely. The court upheld the trial court's credibility determinations — particularly its rejection of plaintiff's key witness, who amended testimony mid-trial after Googling his equipment's accuracy — under the deferential manifest weight standard. The court further confirmed that Rule 137(a) expressly permits sua sponte sanctions, that no evidentiary hearing with sworn testimony was required to determine the fee amount, and that a detailed counsel proffer with opportunity for plaintiff to respond was sufficient.

This decision is significant for litigators because it clarifies that an unresolved Rule 137 sanctions claim suspends appellate finality, and that courts retain broad discretion to impose and quantify sanctions without formal motion practice or sworn fee testimony.

In November 2025, the State filed petitions in Tazewell County alleging minors A.P. and R.P. were neglected due to an injurious environment and that R.P. was abused through excessive corporal punishment by respondent-father Blaykdon P. In December 2025, respondent, through counsel, declined to respond to the petitions invoking his Fifth Amendment right against self-incrimination due to pending criminal litigation, and the trial court entered a default judgment against him. Following an adjudicatory hearing where the State presented evidence by proffer, the court found both minors neglected and R.P. abused. At the dispositional hearing, the court adjudicated the minors wards of the court, found respondent unfit, placed the minors with their mother, and entered a no-contact order against respondent. Respondent appealed, and appointed appellate counsel moved to withdraw pursuant to Anders v. California.

The Fourth District granted counsel's motion to withdraw, finding no meritorious issues on appeal. On the adjudicatory findings, the court held that the invited error doctrine precluded any challenge because respondent himself consented to the default judgment. Even absent that bar, the State's proffered evidence — documenting respondent's excessive corporal punishment of R.P. causing injuries, committed in A.P.'s presence — adequately supported the abuse and neglect findings under a preponderance standard. The court also found no basis for an ineffective assistance claim.

Regarding the dispositional no-contact order, the court found it expressly authorized by the Juvenile Court Act, supported by the evidence and the GAL's report, and provisional in nature. Critically, the court held any challenge was moot because respondent's existing criminal conditional release order already independently prohibited contact with the children, meaning appellate relief would provide no practical benefit. Practitioners should note the interplay between criminal conditional release conditions and juvenile court protective orders, and the application of invited error in default adjudication contexts.

Crystal Davis filed a petition for an emergency and plenary order of protection against Wayman Freelon under the Illinois Domestic Violence Act of 1986, alleging sexual assault and prior strangulation. The trial court issued an emergency order of protection, but after a bench trial on June 9, 2025, found Davis not credible, concluded she failed to prove abuse by a preponderance of the evidence, and denied and dismissed the petition. Davis appealed, challenging both the vacatur of a default plenary order of protection entered on April 23, 2025, and the ultimate denial of her petition.

The First District Appellate Court affirmed on a dispositive threshold ground: Davis failed to prove that Freelon qualified as a 'family or household member' under the Act. The court held that the parties' relationship — a short, secret, non-romantic, purely physical arrangement lasting just over one month that originated from a business inquiry — did not constitute a 'dating relationship' as contemplated by 750 ILCS 60/103(6). Relying on Alison C. v. Westcott, People v. Howard, and McClellan v. Hull, the court emphasized that a dating relationship requires a serious courtship with a significant romantic focus, not merely repeated sexual encounters. Because this finding was dispositive, the court declined to address Davis's arguments regarding the abuse finding, the vacatur of the default order, and alleged trial court errors, treating those issues as either unnecessary to resolve or moot.

For practitioners, this case reinforces that establishing subject matter eligibility under the IDVA — specifically, the 'family or household member' requirement — is a threshold issue that can defeat an order of protection petition regardless of the underlying abuse allegations. Attorneys should carefully assess the nature, duration, and character of the parties' relationship before filing.

Andrew Toms pleaded guilty to aggravated battery with a firearm on the day his jury trial was to begin, receiving a 15-year sentence at 85%. After a prior remand for inadequate Rule 604(d) compliance, new postplea counsel filed a second amended motion to withdraw the guilty plea, which the trial court denied. OSAD filed an Anders motion to withdraw on appeal, concluding the appeal lacked arguable merit. The Fifth District agreed and affirmed.

The court found the trial court's Rule 402 admonishments were thorough and that a written jury waiver existed in the record. Toms's claim that he felt pressured to plead guilty due to the absence of subpoenaed witnesses was directly contradicted by his own statements during the plea proceedings. On the ineffective assistance claims, the court applied the modified Strickland standard and found Toms could not satisfy either prong: plea counsel's decisions not to subpoena two witnesses were reasonable given her inability to contact one and the other's unhelpful account, and Toms provided no witness affidavits to substantiate his claims. His statutory vagueness and renumbering arguments lacked any legal basis, and his mandatory supervised release claim was waived for failure to raise it in the postplea motion.

For practitioners, this case reinforces that bare allegations and self-serving affidavits are insufficient to establish ineffective assistance in the plea withdrawal context, and that Rule 604(d) certificates will withstand scrutiny when they track the rule's language and the record affirmatively corroborates counsel's compliance.

Jesse Garmon was convicted of misdemeanor criminal sexual abuse in 1992 and later triggered sex offender registration obligations through a 2012 felony conviction. After his 2018 release, he registered and subsequently pleaded guilty to a Class 3 felony for failing to comply with registration requirements. In 2024, Garmon filed a declaratory judgment action in Fulton County Circuit Court arguing that the Sex Offender Registration Act (SORA) was unconstitutional as applied to him under the proportionate penalties clause of the Illinois Constitution, and seeking removal from the Registry. The trial court dismissed the complaint under section 2-615 for legal insufficiency, and Garmon appealed.

The Fourth District affirmed, holding that the registration requirements do not constitute punishment or a penalty — a necessary predicate to any proportionate penalties clause claim. The court applied the Illinois Supreme Court's controlling determination in Kopf v. Kelly, 2024 IL 127464, that SORA is not punitive in nature, reasoning that this conclusion does not change based on which constitutional provision frames the challenge. The court rejected Garmon's argument that post-Kopf statutory amendments rendered the scheme punitive, finding that the substantive restrictive provisions he cited predated Kopf and were already considered in that decision, while the actual post-Kopf amendments addressed only definitional changes, LEADS database functions, and name-change procedures — relatively minor adjustments insufficient to alter the statute's non-punitive character.

For practitioners, this decision forecloses proportionate penalties clause challenges to SORA by establishing that Kopf's non-punitive finding applies equally across constitutional theories, and that incremental legislative amendments will not easily reopen that question.

Darrell McLin was convicted by a Winnebago County jury of first degree murder and one count of attempted first degree murder following a June 2021 shooting that killed one victim and injured another. He was sentenced to an aggregate 165 years' imprisonment. On appeal, appointed counsel was permitted to withdraw after McLin elected to proceed pro se. McLin filed his appellate brief in March 2026, raising issues including statutory speedy trial violations, a defective grand jury indictment, prosecutorial misconduct before the grand jury, and ineffective assistance of trial counsel.

The Fourth District never reached the merits of any issue. Instead, the court struck McLin's brief and dismissed the appeal based on pervasive noncompliance with Illinois Supreme Court Rule 341(h). The brief lacked a table of contents, introductory paragraph, statement of issues, jurisdictional statement, conclusion, and appendix. It exceeded the page limit, had a deficient cover page, contained no statement of facts with record citations, and presented only conclusory legal arguments without coherent application of cited authority. Notably, McLin himself acknowledged in a subsequent motion that his brief was 'fundamentally deficient.' The court denied his belated motion to amend, filed only after the State identified the deficiencies and after the reply brief deadline had passed.

The court reaffirmed that pro se litigants are held to the same standards as licensed attorneys and are entitled to no greater leniency. Dismissal, though a harsh sanction, was warranted given the scope of violations, which prevented meaningful appellate review. Attorneys advising incarcerated clients considering self-representation on appeal should use this decision to counsel against that course.

Arlene Staffeldt died testate in May 2023, and her sons Michael and Brandt Staffeldt were appointed independent co-executors. When they scheduled an auction of estate personal property, another son, William Staffeldt, filed for emergency injunctive relief, alleging the auction violated the will. The circuit court of Knox County granted a TRO and later a preliminary injunction prohibiting defendants from selling or disposing of any estate property. After multiple continuances, defendants moved to dissolve the injunction in August 2025, arguing the will's 270-day provision authorized the sale, that William had already received all requested property, and that he had an adequate remedy at law. The circuit court denied the motion, and defendants appealed.

The Fourth District Appellate Court affirmed on all issues. The court held that the abuse-of-discretion standard governs review of a denial of a motion to dissolve a preliminary injunction, rejecting defendants' argument that the will-interpretation question warranted de novo review. The court declined to interpret the will in defendants' favor, reasoning that whether the 270-day provision permitted the sale was itself the triable issue the injunction was designed to preserve. The court also found that plaintiff's inability to view estate property in defendants' possession left a genuine factual dispute warranting preservation of the status quo until trial.

For probate and civil litigators, this case reinforces that a motion to dissolve a preliminary injunction faces a high bar on appeal. Arguments attacking the original basis for the injunction — such as adequacy of legal remedies — are largely irrelevant once the court finds no abuse of discretion in denying dissolution. Unresolved access and inventory disputes can independently sustain injunctive relief through trial.