In re Marriage of Mehta

1. Case citation and parties
- In re Marriage of Mehta, 2024 IL App (3d) 240055-U (Ill. App. Ct., 3d Dist., June 26, 2024). (Rule 23 order — not precedent except as allowed by Rule 23(e)(1)).
- Petitioner/Appellee: Shana R. Mehta. Respondent/Appellant: Neel Mehta.

2. Key legal issues
- Whether the trial court committed manifest error in applying and weighing the statutory relocation factors under 750 ILCS 5/609.2(g) when it granted mother’s petition to relocate the parties’ two young children to North Carolina over father’s objection.
- Distinction between a relocation petition and a modification of allocation; whether the existing allocation (and conditions suspending father’s parenting time) remained intact.

3. Holding/outcome
- Affirmed. The appellate court held the trial court did not commit manifest error in finding relocation was in the children’s best interests and granting the petition.

4. Significant legal reasoning
- The trial court conducted a factor-by-factor analysis under 750 ILCS 5/609.2(g), made credibility findings, and articulated the evidence supporting each factor (GAL report, guardian ad litem testimony, mother’s financial/familial reasons, father’s lack of contact and noncompliance with treatment/evaluation requirements).
- Court emphasized that father had not seen the children for ~18 months and had “substantially failed” to exercise parental responsibilities by not completing recommended evaluations/treatment — diminishing the weight of his objection.
- The court found the relocation would materially benefit the children (financial support and familial network), and the anticipated disruption was limited given father’s minimal present role. It recognized a clear path for father to regain parenting time if he complied with recommendations (supervised then phased unsupervised time; remote visitation options).
- Appellate review applied the deferential “manifest error” standard to credibility and best‑interest determinations; no reversible error shown.

5. Practice implications (concise)
- For objecting parents: actively preserve and demonstrate an ongoing, meaningful parent–child relationship; comply promptly with court‑ordered evaluations/treatment; maintain contact and document attempts to exercise parenting time — failure undermines opposition to relocation.
- For relocating parents: present concrete child‑focused benefits (financial stability, familial support, schooling/community), detailed logistics for preserving parent contact (supervised, virtual, travel arrangements), and GAL/therapist support.
- For trial advocacy: elicit and memorialize credibility findings and factor‑by‑factor analysis; propose specific post‑relocation parenting plans and pathways to reinstate parenting time to reduce appellate vulnerability.