In re Marriage of Springer, 2025 IL App (5th) 220378-U

Published: 1/29/2026
By Jonathan D. Steele
In re Marriage of Springer, 2025 IL App (5th) 220378-U

What should you know about in re marriage of springer, 2025 il app (5th) 220378-u?

Quick Answer: Case Summary: In re Marriage of Springer, 2025 IL App (5th) 220378-U - *In re Marriage of Springer* reinforces that Illinois appellate courts will not disturb trial-level findings on child support, dissipation, or asset classification absent a properly developed evidentiary record—making forensic documentation and asset tracing at trial dispositive rather than optional. The reversal of the contempt orders on procedural due process grounds underscores that even meritorious enforcement actions fail when petitions for rule to show cause lack proper specificity and notice.
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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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