First District Appellate Court

In re Marriage of Lebovich

September 30, 2025
2025 IL App (1st) 230576-U
Nonprecedential Rule 23(b) order

Nonprecedential Rule 23(b) written order. Because it was entered on or after January 1, 2021, it may be cited for persuasive purposes under Rule 23(e)(1), but it is not binding precedent. Status is based on the stored -U public-domain citation; verify the official disposition and later docket history.

Marriage Dissolution
Case Analysis

In re Marriage of Lebovich, 2025 IL App (1st) 230576‑U



1) Case citation and parties
- In re the Marriage of Alissa Lebovich (Petitioner‑Appellee) and Lenny Lebovich (Respondent‑Appellant).
- Appellate Court of Illinois, First District, Sixth Division. Order filed Sept. 30, 2025 (Rule 23, non‑precedential). Consolidated appeals Nos. 1‑23‑0576, 1‑24‑0630, 1‑24‑1307, 1‑25‑1003.

2) Key legal issues
- Whether the trial judge exhibited bias warranting vacatur and remand before a different judge.
- Validity of parenting‑time allocations (summer schedule) and limitations on extracurricular activities.
- Authority to require a parent to provide access (passwords/login) to children’s electronic devices and sanctions/contempt for noncompliance.
- Whether refusing a severance payment constituted dissipation of marital assets.
- Appropriateness of a $200,000 attorney’s‑fees award and related turnover/sanctions.

3) Holding / outcome
- The appellate court rejected the claim of judicial bias and affirmed the Allocation Judgment and Dissolution Judgment in all material respects.
- The requirement that respondent provide full access to the children’s Apple IDs (or change passwords if tied to his personal accounts) was affirmed.
- The court’s limits on extracurricular activities (one team/group sport per season; alternating seasons choice) and the summer/regular parenting‑time regime were affirmed.
- The trial court’s finding that respondent dissipated marital assets (including $62,500 in severance he declined) and the attorney’s‑fees award (approximately $200,000) were affirmed.
- The matters were remanded for further proceedings consistent with the opinion (including turnover and implementation of contempt remedies).

4) Significant legal reasoning (condensed)
- Bias: record did not establish objective judicial partiality; rulings were supported by findings and trial record.
- Parenting time & activities: the court applied best‑interests analysis, credited expert and GAL testimony about overscheduling, fatigue, and primary caregiving; restrictions and a structured alternating selection scheme were viewed as reasonable and consistent with children’s welfare.
- Electronic access: practical control over children’s accounts rested with respondent since Apple IDs were tied to his account; the court imposed an affirmative duty to provide access (or change passwords) to ensure co‑parental oversight — noncompliance justified sanctions and contempt.
- Dissipation: refusing a severance that effectively reduced the marital estate was deemed dissipation where the court rejected respondent’s justification.
- Fees: award justified under statutory factors (need/resources, disparity, prior interim fee equalization and funding by third‑party lender with expectation of repayment).

5) Practice implications
- Orders requiring electronic‑device access are enforceable; noncompliance can trigger substantial sanctions and suspension of parenting time. Draft and litigate device‑access provisions with specificity (who controls accounts, password change obligations, privacy carve‑outs).
- Declining offers or benefits (severance, insurance proceeds, etc.) can be treated as dissipation — counsel should evaluate and document the economic/legal rationale before advising refusal.
- Expert and GAL testimony about children’s scheduling and fatigue can materially influence extracurricular and summer parenting rulings.
- Allegations of judicial bias are difficult to sustain absent clear record support; preserve specific objections and rulings for appeal.
Source Opinion Verify the summary against the opinion and later history
Open Opinion

Questions About Hidden Assets or Dissipation?

Start with a conflict-check intake. If cleared, our office can discuss the relevant financial records and next steps.

Start Conflict-Check Intake

Legal Assistant

This tool answers general questions about the text of this summary. It does not give legal advice, it does not know the facts of your case, and its answers may be wrong.

Disclaimer: This AI analysis is for informational purposes only and does not constitute legal advice. Always verify any AI-generated content against the official court opinion.
Call Intake