In re Marriage of Spangler, 2025 IL App (2d) 240303

What should you know about in re marriage of spangler, 2025 il app (2d) 240303?

Quick Answer: Case Summary: In re Marriage of Spangler, 2025 IL App (2d) 240303 - The article analyzes *In re Marriage of Spangler* (July 2025), where an Illinois appellate court affirmed $78,885.64 in child support arrears against a spouse who failed to provide required annual income documentation, rejecting his defense that informal payment arrangements and the other party's acceptance of tax exemptions constituted an enforceable oral modification. A key legal point established is that parties cannot effectuate out-of-court modifications of child support obligations without court approval, as courts must independently protect children's interests—meaning private deals between parents are unenforceable regardless of how long they've been followed.

undefined

Frequently Asked Questions

How do appellate decisions affect my divorce case?

Illinois appellate decisions interpret statutes and establish binding precedent for trial courts. A relevant appellate ruling can significantly impact your case strategy, available arguments, and likely outcomes. Your attorney should research recent decisions affecting your specific issues.

Can I appeal my divorce judgment in Illinois?

Yes, but appeals are limited to legal errors, not disagreement with factual findings. You must file a notice of appeal within 30 days of the final judgment. Appellate courts review whether the trial court applied the law correctly and whether findings are against the manifest weight of evidence.

What does 'unpublished' mean for Illinois appellate decisions?

Unpublished decisions (marked '-U') may not be cited as precedent under Illinois Supreme Court Rule 23. While they show how courts analyze issues, they don't establish binding legal rules. Published decisions create precedent that lower courts must follow.

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.

Free Case Assessment

For more insights, read our Divorce Decoded blog.

Serving Chicago & Suburbs

Gold Coast Streeterville Ukrainian Village Lincoln Square Near North Side Lincoln Park River North Lakeview Wicker Park Old Town West Loop The Loop

Cook County Lake County DuPage County Will County Kane County