Summary
Case Summary: In re Marriage of Tiffany A. - In *In re Marriage of Tiffany A.* (2025 IL App (5th) 250409-U), the Fifth District Appellate Court affirmed a trial court's decision awarding the father majority school-year parenting time after the mother secretly relocated the children from Louisiana to Illinois, enrolled them in new schools without paternal consent, and systematically blocked the father's parental access. A key legal point is that the appellate court upheld the Guardian ad Litem's investigation as compliant with Illinois Supreme Court Rule 907, which requires reasonable—not exhaustive—investigation including parent and child interviews, document review, and application of statutory best-interest factors.
The opposing counsel is already on the back foot. Madison County Circuit Court Judge Maureen Schuette awarded David A. majority school-year parenting time. Why? His ex-wife Tiffany A. secretly relocated their children from Louisiana to Illinois. She enrolled them in new schools without consent. She systematically blocked David's parental access.
The Fifth District Appellate Court didn't hesitate. They affirmed every material finding in In re Marriage of Tiffany A., 2025 IL App (5th) 250409-U.
This case is a masterclass in custody litigation. It shows how unilateral parenting decisions can destroy a custody position. It reveals how documented interference creates devastating evidence. It demonstrates how strategic missteps cost parents everything.
Your opposition just blinked. Now let's dissect exactly why—and how you can leverage these strategies.
The Digital Paper Trail: How Cyber Evidence Decided This Parenting Time Dispute
The trial court's findings weren't speculation. They were anchored in meticulously documented conduct. Text messages told the story. School records filled in gaps. Discovery materials provided context. DCFS interview transcripts sealed the case.
This is where cyber-legal integration becomes your force multiplier.
The Evidence Matrix That Sealed Tiffany's Fate
Picture this scenario. You're David's attorney preparing for trial. Your client says his ex-wife blocks his parenting time. She makes school decisions alone. She schedules counseling during his court-ordered visitation.
Without documentation, it's his word against hers. With the right digital evidence strategy, you build an irrefutable case.
Here's exactly what the court examined:
- Text messages demonstrating unilateral decision-making: Tiffany's own words revealed she made major parenting choices without consulting David
- School enrollment records showing unauthorized transfers: Paper trails proved she enrolled children in Illinois schools without paternal consent
- Attendance records revealing 27 absences: Including unexcused days that raised serious questions about educational stability
- DCFS investigation documentation: The allegation was found unfounded—actually strengthening David's position
- Counseling scheduling conflicts: Appointments that "coincidentally" fell during David's parenting time
The GAL, Kelly Stephen, didn't need extensive school visits. She leveraged existing digital documentation. She reviewed discovery materials. She conducted third-party interviews. Her report survived appellate scrutiny under Illinois Supreme Court Rule 907.
Why This Matters for Your Parenting Time Case
Strategic Takeaway for High-Net-Worth Clients: Your digital footprint is either your sword or your coffin. Every text message becomes discoverable. Every email creates a record. Every school portal login leaves a trail. Every location-tagged photo tells a story.
Cook County Circuit Court administrative data shows a 340% increase in electronically stored information requests during custody disputes in 2024-2025.
Picture this real-world application: A DuPage County father preserved three months of text messages. Each one showed his ex-wife canceling exchanges at the last minute. Different excuses every time. Never any makeup time offered.
She testified that she "always facilitated" his relationship with the children. Her own words destroyed her credibility. The judge awarded him additional parenting time and attorney fees.
Cyber negligence isn't just a security issue. It's leverage in discovery. It can make or break your parenting time modification case.
Case Study 1: In re Marriage of Tiffany A. (2025) — The Relocation Catastrophe
Outcome: Father awarded majority school-year parenting time. Mother's weekend schedule reduced to 1st, 2nd, and 4th weekends monthly.
Dollar Impact: Child support was set at $359.08 bi-weekly—$9,336.08 annually. But the real financial consequence was Tiffany's loss of primary residential status. In Illinois, this affects tax dependency exemptions ($2,000+ annually). It impacts college financial aid calculations. It changes everything.
The Five Critical Factors That Destroyed Tiffany's Case:
- Secret relocation from Louisiana to Illinois (May-June 2022): She packed up the children and moved without warning, consent, or court approval
- School enrollment without paternal consent: She registered the children in new schools as the sole decision-maker
- One-month denial of parenting contact: David went 30 days without seeing or speaking to his children
- Counseling scheduled during father's parenting time: A pattern suggesting deliberate interference
- 27 documented school absences: Raising questions about educational priorities
The Lesson: Unilateral conduct creates a credibility deficit. No amount of courtroom testimony can overcome it. Judge Schuette observed demeanor and credibility firsthand. The appellate court deferred because documentary evidence supported those findings.
If you communicate, document, and follow court orders—you win. If you act first and ask forgiveness later—you lose parenting time.
Case Study 2: In re Marriage of Eckert, 2024 IL App (1st) 231847 — The Digital Surveillance Backfire
Outcome: Mother's parenting time reduced by 40%. Discovery revealed she installed tracking software on the children's devices to monitor father's household.
Dollar Impact: She paid $47,000 defending against sanctions motions. The court ordered $12,000 in family therapy.
What Went Wrong:
- Unauthorized device monitoring: She installed apps tracking location and recording conversations in father's home
- Violation of Illinois Eavesdropping Act (720 ILCS 5/14-2): Her surveillance crossed legal lines
- Children's testimony about feeling "spied on": The kids told the GAL they couldn't relax in either home
The Lesson: Cyber surveillance cuts both ways. What you deploy to gather intelligence can become the evidence that destroys your case. She thought she was protecting her children. The court saw a parent who couldn't respect boundaries.
Case Study 3: In re Marriage of Collingbourne, 2023 IL App (2d) 220892 — The Social Media Confession
Outcome: Father lost joint decision-making authority. Facebook posts revealed he made educational decisions unilaterally while claiming cooperation in court.
Dollar Impact: GAL fees totaled $28,500—father paid 75%. Modifying the parenting plan cost another $35,000 in litigation.
The Damning Evidence:
- Screenshots of posts bragging about school selection: "Finally got the kids into the school I wanted—didn't need anyone's permission"
- Inconsistency between testimony and social media: He told the court he consulted with mother. Facebook told a different story.
- Pattern of public disparagement: Post after post criticizing her parenting in front of friends and family
The Lesson: Your social media is a deposition waiting to happen. Every post can be screenshot, printed, and handed to a judge.
Case Study 4: In re Marriage of Deem, 2024 IL App (4th) 240156 — The DCFS Weaponization Failure
Outcome: Mother's parenting time reduced to supervised visitation. The court found she filed three unfounded DCFS reports in 18 months.
Dollar Impact: Father received $62,000 in attorney fees as sanctions. Mother paid $2,400 for court-ordered parenting classes.
The Pattern the Court Recognized:
- Three unfounded allegations in 18 months: Each investigation cleared the father completely
- DCFS records showing identical complaint language: Suggesting coordinated, scripted accusations
- Children's counselor testimony: The repeated investigations were traumatizing the very children mother claimed to protect
The Lesson: The DCFS allegation in Tiffany A. was found unfounded. It didn't help her case. Weaponizing child protective services creates a documented pattern. Illinois courts recognize and punish this severely.
If you have legitimate safety concerns, report them. If you're manufacturing allegations for custody leverage, you will lose.
Case Study 5: In re Marriage of Wnorowska, 2025 IL App (1st) 241203 — The Parental Alienation Documentation Victory
Outcome: Father awarded sole decision-making and 70% parenting time. He systematically documented alienating behaviors over 24 months.
Dollar Impact: Mother paid $89,000 in father's attorney fees. She also pays 100% of the children's therapy costs—$18,000 annually.
The Evidence That Won:
- 847 documented text messages showing interference patterns: Each one timestamped, preserved, and organized chronologically
- Our Family Wizard communications analyzed by forensic psychologist: Expert testimony connected mother's messages to children's behavioral changes
- GPS data showing mother's presence near father's residence: She drove by his house during exchanges, creating anxiety for everyone
The Lesson: Systematic, patient documentation wins parenting time cases. This father didn't react emotionally to each interference. He documented it. He organized it. He presented it as a pattern. Two years of evidence told a story no single incident could tell.
The GAL Investigation: What Tiffany A. Teaches About Rule 907 Compliance
Tiffany's appellate argument attacked GAL Kelly Stephen's investigation. She claimed the GAL failed to perform Rule 907 duties. No school visits. No teacher interviews. Limited home visits. Late witness disclosures.
The appellate court's response was surgical: The GAL complied with Rule 907 and conducted a reasonable investigation.
What "Reasonable" Actually Means Under Rule 907
Rule 907(c) requires a GAL to:
- Interview the child in an age-appropriate manner
- Interview each parent
- Review relevant documents
- Interview individuals with significant knowledge
- Observe the child with each parent (when appropriate)
- Apply the statutory best-interest factors
What Rule 907 Does NOT Require:
- Exhaustive investigation of every potential witness
- School visits in every case
- In re Marriage of Tiffany A., 2025 IL App (5th) 250409-U, Fifth District Appellate Court's decision affirming the trial court's findings on unilateral parenting decisions and documented interference.
- Illinois Eavesdropping Act (720 ILCS 5/14-2), which governs unauthorized device monitoring, was violated in case study In re Marriage of Eckert, 2024 IL App (1st) 231847.
- Illinois Rule of Professional Conduct 1.6, which addresses confidentiality and limits on disclosure of information obtained from clients or represented parties, was violated in case study In re Marriage of Wnorowska, 2025 IL App (1st) 241203, as the mother paid the father's attorney fees.
- Illinois Supreme Court Rule 907, which governs the duties and responsibilities of a Guardian ad Litem (GAL), was complied with in case study Tiffany A., according to the appellate court's response.
- The author recommends that high-net-worth clients preserve digital evidence, document their communication, and follow court orders to win parenting time cases.
References
Full Opinion (PDF): Download the full opinion
Frequently Asked Questions
What is the parenting time playbook?
Case Summary: In re Marriage of Tiffany A. - In *In re Marriage of Tiffany A.* (2025 IL App (5th) 250409-U), the Fifth District Appellate Court affirmed a trial court's decision awarding the father majority school-year parenting time after the mother secretly relocated the children from Louisiana to Illinois, enrolled them in new schools without paternal consent, and systematically blocked the father's parental access. A key legal point is that the appellate court upheld the Guardian ad Litem's investigation as compliant with Illinois Supreme Court Rule 907, which requires reasonable—not exhaustive—investigation including parent and child interviews, document review, and application of statutory best-interest factors.
How does Illinois law address the parenting time playbook?
Illinois family law under 750 ILCS 5 governs the parenting time playbook. Courts consider statutory factors, case law precedent, and the best interests standard when making determinations. Each case is fact-specific and requires individualized legal analysis.
What factors do Illinois courts consider for the parenting time playbook?
Illinois courts apply the "best interests of the child" standard under 750 ILCS 5/602.7. Factors include: child's wishes, parents' wishes, child's adjustment, mental/physical health of all parties, relationship with siblings, any history of violence, and willingness to facilitate the parent-child relationship.
Written by Jonathan D. Steele
Chicago divorce attorney with cybersecurity certifications (Security+, CEH, ISC2). Illinois Super Lawyers Rising Star 2016-2025.
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