Wright's Digest

In re Marriage of Hipes

Key takeawayThe court affirmed parenting-time restrictions supported by findings of serious endangerment and tailored to protect the child under §603.10. A restrictions request requires the statutory findings; it is distinct from ordinary best-interests allocation.

Read the decision — ¶¶ 43–54. Source checked September 28, 2026.

A separate 2025 appeal concerns counsel disqualification, contempt and attorney fees. It affirmed disqualification and some fee awards while reversing other fees; it did not reverse the parenting-restrictions holding.

2025 related appeal, ¶ 1

Reynolds v. Reynolds

Key takeawayOn September 24, 2026, the Illinois Supreme Court held that a motion seeking to modify parenting time only is governed by §610.5(a): changed circumstances necessitating modification to serve the child’s best interests, without the substantial-change requirement of subsection (c). It affirmed the Second District and overruled Trapkus to the extent inconsistent. Decision-making, restrictions and statutory exceptions require their own analysis.

Read the decision — ¶¶ 38–44, 48–51. Source checked September 28, 2026.

Opinion filed September 24, 2026; court posting marked Slip when checked. Rehearing remains possible.

Affirms 2025 IL App (2d) 240028. This entry now describes the Supreme Court decision, not an unresolved district split.

For your situation: What kind of parenting change are you seeking? Separate a parenting-time request from decision-making and restrictions before evaluating the governing standard.

In re Marriage of Royer

Key takeawayThe court reversed an increase from zero to 26 annual overnights under the minor-modification exception in §610.5(e)(2). Given the existing supervision requirements and unresolved medical evidence, the change was not minor and the best-interests finding was unsupported. The holding concerns that statutory exception; it is not a rule that every parenting-time request requires a substantial change.

Read the decision — ¶¶ 32–37. Source checked September 28, 2026.

In re Marriage of Gorr

Key takeawayThe court reversed and remanded for separate analyses of removing a medical decision-making restriction under §603.10(b) and modifying joint decision-making under §§602.5 and 610.5(c). Removing the therapy-cooperation requirement required a child-focused best-interests analysis; the decision-making requests required the applicable substantial-change and best-interests analysis. The appellate court did not itself award either parent sole authority.

Read the decision — ¶¶ 37–50. Holding source checked September 28, 2026.

Kush v. Kush

Key takeawayHeld that agreed terms effectively preventing a parent from seeking modification or contacting a child could violate public policy because children’s best interests cannot be bargained away.

Rule 23 order; not precedent except as permitted by Rule 23(e)(1).

Read the official order.

In re Parentage of D.F.

Key takeawayThe court held that the petitioner’s allegations of intended parentage, participation in assisted reproduction and support gave her standing under the Parentage Act. Standing allowed her claim to proceed; it was not a final adjudication that she was a legal parent.

Read the decision — ¶¶ 27–34. Source checked September 28, 2026.

In re Marriage of Tener

Key takeawayThe court rejected a claim that appointing a guardian ad litem for an adult litigant was void for lack of jurisdiction, then dismissed the appeal because the challenged interlocutory orders were not final and appealable under Rule 304(a). This jurisdictional decision should not be presented as an unrestricted power to appoint an adult guardian ad litem.

Read the decision — ¶¶ 11–24. Source checked September 28, 2026.

In re Marriage of Jessica F.

Key takeawayThe court upheld the decision not to interview the child in chambers. Section 604.10(a) permits, but does not require, an interview to learn the child’s wishes; it is not a device for investigating alleged events. The record supported the exercise of discretion despite the absence of an express ruling on the interview motion. The parties could have offered other evidence of the child’s wishes.

Read the decision — ¶¶ 36–45. Holding source checked September 28, 2026. The official published opinion records denial of rehearing on June 6, 2024. This entry addresses the interview ruling; for the current parenting-time modification standard, see Reynolds above.

In re Marriage of Alpert Knight

Key takeawayThe court reversed the finding that a substantial increase in the supporting parent’s income did not constitute a substantial change in circumstances. It remanded for consideration of whether, and by how much, to modify support, including the children’s expected standard of living. It did not order an automatic increase. Its foreseeability analysis applied the statutory version governing the motion filed in 2021; current requests require review of the applicable §510.

Read the decision — ¶¶ 23–25, 31–44. Holding source checked September 28, 2026.

In re Marriage of Spangler

Key takeawayThe court affirmed support arrears and civil contempt under the written parenting agreement. Annual income disclosure and updated support calculations were not limited to second-job earnings. The alleged oral modification lacked court approval, and the parent who withheld income information could not reasonably rely on acceptance of lower payments to establish equitable estoppel. The ruling enforces the particular order’s terms; it does not replace today’s support formula.

Read the decision — ¶¶ 19–28. Holding source checked September 28, 2026.

In re Marriage of Moriarty

Key takeawayThe court reversed dismissal of a request for support for an adult child with a disability. Under §513.5(a), an application may be made before or after majority, but the disability must have arisen while the child was eligible for support under §505 or §513. Reaching adulthood or graduating from high school does not alone establish emancipation for this purpose. The case was remanded; it did not establish automatic support for every adult child living at home.

Read the decision — ¶¶ 18–26. Source checked September 28, 2026.

In re Marriage of Miller

Key takeawayThe majority reversed the denial of a petition to terminate maintenance and remanded. Despite separate homes and finances, the couple’s extensive integration of their families and personal lives established a de facto marriage on this record. Separate accounts or residences are not conclusive. A dissent would have deferred to the trial court’s contrary finding; that was not the majority’s holding.

Read the decision — ¶¶ 62–69, 80–85. Holding source checked September 28, 2026.

For your situation: Could a relationship affect maintenance? Review the order and the whole relationship, not just shared addresses or bank accounts. Compare Saunders below.

In re Marriage of Saunders

Key takeawayThe court reversed termination of maintenance because the evidence established an intimate dating relationship, not a de facto marriage. The couple’s separate day-to-day lives, lack of shared commitments and limited practical integration mattered in the overall assessment. The decision does not create a rule that separate homes or finances always prevent a cohabitation finding.

Read the decision — ¶¶ 20–24, 38–42. Holding source checked September 28, 2026.

For your situation: Is dating enough to terminate maintenance? The evidence must be assessed under the applicable legal standard. Compare Miller above rather than treating one factor as decisive.

In re Marriage of Larsen / Edson

Key takeawayBoth decisions affirmed denial of maintenance termination on their particular records. Larsen emphasized the couple’s choices not to deepen their commitment or integrate their families and resources. Edson recognized a long romantic relationship involving family activities but found that practical and economic separation supported the trial court’s result. Neither makes separate residences, separate finances or occasional overnight stays a decisive test by itself.

Read the decision — Larsen ¶¶ 159–175; Edson — ¶¶ 154–165, 183–187. Holding source checked September 28, 2026.

In re Marriage of Durchslag

Key takeawayThe court affirmed denial of maintenance modification: unemployment already existed when maintenance was set, and voluntary depletion of assets on a horse business did not establish the claimed substantial change. It also upheld the contempt-related fee award. This fact-specific Rule 23 order does not establish that every job loss is irrelevant.

Read the decision — ¶¶ 19–28, 30–38. Source checked September 28, 2026.

Rule 23 order; not precedent except as permitted by Rule 23(e)(1).

In re Marriage of Hyman — 2023 asset decision

Key takeawayThe court enforced the settlement’s undisclosed-asset clause against stock options the husband had not disclosed. This was enforcement of the agreement, not a general reopening of every completed property division. The agreement’s language and the actual disclosure record controlled.

Read the decision — ¶¶ 11–20. Source checked September 28, 2026.

In re Marriage of McLean

Key takeawayThe court upheld the Hunt apportionment used for the mixed AT&T retirement account under the facts presented. It separately vacated the Mastercard account allocation because the trial court improperly deducted marital contributions associated with temporary support calculations. The decision does not prescribe one universal formula for every retirement account; account history and the issue being decided matter.

Read the decision — ¶¶ 52–68. Holding source checked September 28, 2026. The decision was initially a Rule 23 order; publication was granted August 18, 2025. The linked source is the published opinion.

For your situation: How should you prepare a mixed retirement account? Identify the plan type and preserve the account history before assuming that a particular formula applies.

In re Marriage of Gabrys

Key takeawayThe court reversed an order requiring immediate sale of the marital home before the divorce judgment. Section 501(a)(3) permits asset sales in appropriate circumstances, but there was no exigency justifying this sale to preserve the status quo. Paying the mortgage and taxes on the marital property was not dissipation on these facts. The case is not an absolute prohibition on pre-judgment sales.

Read the decision — ¶¶ 9–15. Holding source checked September 28, 2026.

In re Marriage of Xinos

Key takeawayThe court affirmed after finding that the spouse had forfeited his challenge to exclusion of evidence about allegedly nonmarital accounts, including by failing to make an offer of proof. It also held that, even without forfeiture, the discovery sanction was within the trial court’s discretion and the nonmarital claims lacked supporting evidence. Timely disclosure and preservation of excluded evidence both mattered.

Read the decision — ¶¶ 26–39. Holding source checked September 28, 2026. The linked official published opinion lists June 17, 2025, as its filing date and June 11, 2025, as the rehearing-denial date. It is used here instead of the earlier May version.

For your situation: What should a review of an ongoing divorce cover? Include discovery orders, missing evidence and upcoming deadlines. This decision concerns evidence and procedure, not substitution of counsel.

Mowen v. Kelly

Key takeawayThe court directed judgment for the former spouse who remained the named retirement beneficiary. Awarding the accounts to their owner in the divorce judgment did not specifically waive her beneficiary expectancy. The record did not establish a trust to which the Trust Code’s revocation provision applied. The actual designation, judgment language and governing account law require review.

Read the decision — ¶¶ 14–30. Holding source checked September 28, 2026.

In re Marriage of Micheli

Key takeawayThe court reversed an unexplained award of all unvested options and RSUs to one spouse; uncertain vesting or value did not prevent equitable division. Separately, it rejected an uncapped bonus-based maintenance award unsupported by the evidence. The 2014 maintenance analysis predates today’s guideline formulas.

Read the decision — ¶¶ 25–26, 32–41. Source checked September 28, 2026.

For your situation: How should you prepare equity awards for review? Build a grant-by-grant record of purpose, vesting, taxes and employment conditions.

In re Marriage of Tronsrue

Key takeawayThe Supreme Court enforced a voluntarily agreed marital-settlement obligation to pay a former spouse a share of veterans’ disability benefits after receipt. The decision concerns enforcement of that agreement; it does not authorize a court to divide otherwise protected disability benefits as ordinary marital property.

Read the decision — ¶¶ 35–49. Source checked September 28, 2026.

The U.S. Supreme Court denied certiorari on January 12, 2026, No. 25-500. Denial of review is not a decision endorsing the merits.

Certiorari denial, order list p. 6

McClellan v. Hull

Key takeawayThe court reversed emergency and plenary orders of protection because the evidence did not establish the qualifying dating relationship under the Domestic Violence Act. The limited encounters and potential relationship were insufficient on this record. It separately affirmed denial of the other party’s civil no-contact petition. The relationship requirement is fact-specific and should not be reduced to a fixed number of dates.

Read the decision — ¶¶ 64–74, 84–85. Holding source checked September 28, 2026.

Martinez v. Leon

Key takeawayThe court treated the respondent’s remote appearance, with the protective order’s operative terms read in open court, as personal service under the governing administrative order, later codified in Rule 102.1. It vacated the refusal to decide an uncontested request for temporary child support within the protective-order proceeding. The petitioner was entitled to a merits decision, not an automatic support award.

Read the decision — ¶¶ 22–27, 30–32. Holding source checked September 28, 2026.

Graham v. Van Rengen

Key takeawayThe court affirmed contested two-year extensions of plenary orders of protection. Under §220(e), a fixed extension of no more than two years required satisfaction of §219; an indefinite contested extension also required good cause. The court considered the history of abuse and the record supporting continued protection. A new violation of the original order was not an indispensable prerequisite.

Read the decision — ¶¶ 45–55, 60–65. Holding source checked September 28, 2026.

In re Parentage of A.C.

Key takeawayThe court classified the courtroom misconduct as direct criminal contempt and left the criminal fines intact. It reversed the indefinite incarceration and purported purge requirements because punishment for criminal contempt cannot use an open-ended civil-contempt release condition. The sanction’s purpose and substance control its classification, rather than the label placed on the order.

Read the decision — ¶¶ 18–28. Holding source checked September 28, 2026.

In re Marriage of Hyman — 2024 fees decision

Key takeawayOnce the predicate for §508(b) enforcement fees is established, reasonable fees are mandatory, including qualifying appellate enforcement work. The court required reasons for reductions and rejected denial of mandatory postjudgment interest. This 2024 appeal addresses fees and interest after the separate 2023 undisclosed-asset decision.

Read the decision — ¶¶ 7–20. Source checked September 28, 2026.

In re Marriage of Harnack

Key takeawayThe court affirmed denial of a motion to vacate civil-contempt incarceration for failure to transfer stock awarded in a divorce. The contemnor failed to show that the sanction had lost its coercive effect. Time in custody alone did not decide that question; ability to comply and the evidentiary record mattered.

Read the decision — ¶¶ 1–3, 125–132. Source checked September 28, 2026.

Rule 23 order; not precedent except as permitted by Rule 23(e)(1). The official PDF and court listing display 2025 IL App (1st) 240835 without a -U suffix.

In re Marriage of Heroy

Key takeawayThis 2008 decision affirmed permanent maintenance after a 26-year marriage, considering the marital standard of living, career sacrifices, earning prospects and available resources. It predates Illinois’s statutory maintenance formulas and should not be cited as a guideline-calculation decision.

Read the decision — Opinion PDF pp. 16–23. Source checked September 28, 2026.

In re Marriage of Dann

Key takeawayThe court reversed summary judgment classifying disputed business-related assets as nonmarital because material factual issues remained. Payments received during marriage from a nonmarital business are presumptively marital; a spouse relying on §503(a)(8) must establish that they qualify as income from nonmarital property and are not attributable to personal effort. Minority ownership alone did not satisfy that burden. The decision did not finally classify every disputed asset.

Read the decision — ¶¶ 74–86, 168–169. Holding source checked September 28, 2026. Source: opinion filed July 20, 2012, as amended (reprint).

For your situation: Are business payments separate property? Organize the ownership history and the records explaining each payment before comparing buyout proposals.

In re Marriage of Hunt

Key takeawayHunt treated retirement benefits earned during marriage as marital property even when payment or vesting remained uncertain. It discussed both present-value allocation with an offset and division when benefits are paid, using a marital-service fraction. This historical decision does not make one method mandatory for every plan. Current statutes, plan terms and later decisions must govern implementation.

Read the decision — 78 Ill. App. 3d at 663–664 (opinion reprint); Later application: McLean — ¶¶ 55–59. Holding source checked September 28, 2026.

In re Marriage of Fatkin

Key takeawayThe Supreme Court upheld a relocation order supported by the trial court’s detailed best-interests findings. A reviewing court must not substitute its assessment of the evidence absent manifest-weight error. The relocation order was immediately appealable under Rule 304(b)(6).

Read the decision — ¶¶ 27–35. Source checked September 28, 2026.

In re Marriage of Gosney

Key takeawayThe court reversed income imputation where the record showed involuntary job loss, good-faith efforts to find comparable work and no available employment supporting the imputed amount. Its historical analysis must be read alongside today’s §505(a)(3.2a)–(3.2b), including the hearing-or-agreement requirement and specific written findings.

Read the decision — Opinion PDF pp. 7–11. Source checked September 28, 2026.

750 ILCS 5/602.7

Key takeawayParenting time is allocated according to the child’s best interests, considering all relevant factors under §602.7(b), including caretaking history, the child’s needs and reasoned wishes, adjustment, practical schedules, violence and abuse. The section presumes parental fitness, not equal parenting time. Statutory restrictions require the serious-endangerment finding; ordinary allocation and restrictions are distinct. Conduct unrelated to the parent’s relationship with the child is excluded under subsection (c).

Read the statutory source — §602.7(a)–(c). Holding source checked September 28, 2026.

750 ILCS 5/505(a)(3.2a)–(3.2b)

Key takeawayFor voluntary unemployment or underemployment, potential income is determined from the parent’s circumstances and the local labor market. Imputation requires an evidentiary hearing or the parties’ agreement and specific written findings identifying its basis. Incarceration is not voluntary unemployment for this purpose.

Read the statutory source. Source checked September 28, 2026.

750 ILCS 5/600(g)

Key takeawaySection 600(g) uses surface-road distance measured by an Internet mapping service; if alternatives are offered, the shortest-distance alternative is used. The in-state threshold is more than 25 miles from the child’s primary residence in Cook, DuPage, Kane, Lake, McHenry or Will County and more than 50 miles from other Illinois counties. An out-of-state move has a more-than-25-mile threshold.

Read the statutory source. Source checked September 28, 2026.

Karina’s Law — civil and criminal protective orders

Key takeawayKarina’s Law addresses firearm restrictions, surrender and search warrants in qualifying protective-order proceedings. For civil Domestic Violence Act proceedings, consult 750 ILCS 60/214(b)(14.5); 725 ILCS 5/112A-14 addresses the criminal-proceeding counterpart. A warrant requires the specified sworn evidence and findings, including credible threat and probable cause; issuance is not automatic in every protective-order case.

Read the statutory source. Source checked September 28, 2026.

750 ILCS 5/602.10(i)

Key takeawayAn approved parenting plan or allocation judgment is final for modification and appeal even while other issues remain pending. Section 602.10(i) also states that it is void and unenforceable if the underlying action is subsequently dismissed.

Read the statutory source. Source checked September 28, 2026.