In re Marriage of Pace, 2025 IL App (2d) 240392-U

Published: 2/2/2026
By Jonathan D. Steele
In re Marriage of Pace, 2025 IL App (2d) 240392-U

What should you know about in re marriage of pace, 2025 il app (2d) 240392-u?

Quick Answer: Case Summary: In re Marriage of Pace, 2025 IL App (2d) 240392-U - The Illinois Second District Court of Appeals in *In re Marriage of Pace* vacated a child support modification order, ruling that summary procedures under the Illinois Marriage and Dissolution of Marriage Act apply only to temporary support, not contested permanent support modifications, which require full evidentiary hearings. The court found the trial court abused its discretion by imputing income and issuing findings without taking evidence or having complete financial discovery, such as W-2s and 1099s, in the record.
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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).

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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