In re Marriage of Norris

1. Case citation and parties
- In re Marriage of Norris, 2024 IL App (2d) 240219-U (Ill. App. Ct. 2d Dist., order filed Aug. 19, 2024) (Rule 23(b) non‑precedential).
- Petitioner‑Appellant: Megan K. Norris. Respondent‑Appellee: Jeffrey Norris.

2. Key legal issues
- Whether the trial court abused its discretion in granting respondent’s petition for leave to relocate with the parties’ four children to Washington.
- Application of the Illinois Marriage and Dissolution of Marriage Act relocation framework (notice and petition procedures under 750 ILCS 5/609.2(f)) and the statutory “best interests of the child” factors.

3. Holding/outcome
- The appellate court affirmed the trial court’s order permitting Jeffrey to relocate with the children to Washington.

4. Significant legal reasoning (condensed)
- Standard of review: abuse of discretion. The court reviewed the record for whether the trial court reasonably found relocation served the children’s best interests.
- Evidence considered included: ages of the children (17, 15, 13, 11), their expressed preferences (three were willing or indifferent; one reluctant because of friends; eldest wanted to move), the guardian ad litem’s long‑term rapport and recommendation (endorsed relocation with conditions and recommended reunification counseling before unsupervised maternal visitation), history of strained parent‑child relationship and supervised maternal visits, practical relocation facts (respondent’s need to move from rented home, inability to find affordable local housing, available four‑bedroom housing with respondent’s parents in Washington, family support, and better‑rated schools), respondent’s offer to fund maternal travel (airfare twice yearly) and to promote ongoing electronic contact, and lack of concrete local housing/employment alternatives.
- The court credited the trial court’s balancing of stability, safety/history, children’s wishes, educational opportunities, and proposed plans to preserve mother‑child contact. The expedited hearing and limited time to retain counsel were not held to be reversible error under the circumstances.

5. Practice implications for family attorneys
- Relocation petitions must present concrete, credible plans: housing, financial support, employment prospects (or reliable family support), school information, and proposed parenting/visitation logistics (travel costs, frequency, virtual contact).
- Document childrens’ preferences and GAL/counselor assessments; courts give weight to older children’s wishes and GAL impressions.
- If parenting is currently supervised or relationships strained, propose reunification therapy and a clear staged plan for unsupervised visitation to address reunification concerns.
- Be prepared for expedited relief where move deadlines exist; timely preservation of objections and requests for continuances or counsel (and compliance with statutory notice) is critical.