In re Marriage of Isom, 2025 IL App (3d) 240491-U

What should you know about in re marriage of isom, 2025 il app (3d) 240491-u?

Quick Answer: Case Summary: In re Marriage of Isom, 2025 IL App (3d) 240491-U - In *In re Marriage of Isom*, the Third District affirmed the denial of a father's request to reduce his $909 monthly child support obligation after he claimed loss of work authorization, finding that the trial court had determined his change in circumstances was voluntary rather than involuntary. Critically, the appellate court applied the *Foutch v. O'Bryant* doctrine—which presumes the trial court acted properly when an appellant fails to provide an adequate record—because Kareem submitted no transcript, bystander's report, or supporting documentation on appeal.

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Frequently Asked Questions

How is child support calculated in Illinois?

Illinois uses the income shares model under 750 ILCS 5/505. Both parents' net incomes are combined, a basic support obligation is determined from statutory guidelines, and each parent pays their proportionate share. Adjustments apply for parenting time exceeding 146 overnights (40%).

What income counts for Illinois child support calculations?

Net income includes salary, wages, bonuses, commissions, self-employment income, rental income, and most other earnings. Courts can impute income if a parent is voluntarily unemployed or underemployed. Certain expenses like health insurance premiums and prior support obligations are deducted.

When can child support be modified in Illinois?

Under 750 ILCS 5/510, modification requires a substantial change in circumstances. Examples include 20%+ income change, job loss, disability, or significant changes in the child's needs. Support automatically continues until age 18 (or 19 if still in high school).

Written by Jonathan D. Steele

Chicago divorce attorney with cybersecurity certifications (Security+, ISC2 CC, Google Cybersecurity Professional Certificate). Illinois Super Lawyers Rising Star 2016-2025.

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