In re Marriage of Kreps, 2025 IL App (5th) 250053-U

Published: 2/14/2026
By Jonathan D. Steele
In re Marriage of Kreps, 2025 IL App (5th) 250053-U

What should you know about in re marriage of kreps, 2025 il app (5th) 250053-u?

Quick Answer: Case Summary: In re Marriage of Kreps, 2025 IL App (5th) 250053-U - *In re Marriage of Kreps* establishes that Illinois appellate courts will reverse relocation and parenting modification orders when trial courts fail to articulate specific factual findings connecting evidence to each statutory factor under Section 609.2, regardless of whether the underlying decision was substantively correct. This creates both a defensive obligation for prevailing parties to secure detailed findings before judgment becomes final and an appellate pathway for losing parties to challenge conclusory rulings that skip the mandatory analytical framework.
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Frequently Asked Questions

Can I move out of state with my child after divorce in Illinois?

Only with the other parent's written consent or court approval under 750 ILCS 5/609.2. You must provide 60 days written notice including new address, moving date, reason for relocation, and proposed revised parenting schedule. Moves over 25 miles within Illinois or any out-of-state move require formal notice.

What factors do Illinois courts consider in relocation cases?

Under 750 ILCS 5/609.2(g), courts evaluate: the child's wishes, reasons for the proposed move, quality of life improvements, each parent's motives, feasibility of preserving parent-child relationships, and any prior agreements regarding relocation.

What happens if I move without court permission?

Relocating without consent or court approval can result in contempt of court, immediate return of the child, loss of decision-making authority, reduced parenting time, attorney fee sanctions, and potential criminal charges for custodial interference under 720 ILCS 5/10-5.

Jonathan D. Steele

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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