In re Marriage of Jones

1. Case citation and parties
- In re Marriage of Jones, No. 1-25-0259, 2025 IL App (1st) 250259‑U (1st Dist. Nov. 19, 2025) (Rule 23 order; non‑precedential).
- Petitioner‑Appellee: Ryan Jonathan Jones. Respondent‑Appellant: Lindsay Thai Le Jones.

2. Key legal issues
- Whether the trial court abused its discretion or issued a decision contrary to the manifest weight of the evidence in: (a) allocating parenting time unequally; and (b) awarding husband sole decision‑making authority over child’s education, medical, religious and extracurricular matters.
- Whether the trial court properly classified and distributed marital property, considered all marital assets, and adjudicated dissipation claims.
- Whether the maintenance award was supported by current income evidence.

3. Holding / outcome
- Affirmed in part and reversed in part.
- The Appellate Court held the trial court did not abuse its discretion in awarding unequal parenting time and sole decision‑making to Ryan.
- The court reversed and remanded the property/maintenance disposition: trial court erred by failing to consider a marital asset, improperly classifying certain property, and failing to adjudicate dissipation claims—requiring reconsideration of the property award and the related maintenance determination.

4. Significant legal reasoning (condensed)
- Custody/decision‑making: The record supported the court’s findings. The GAL and a custody evaluator provided evidence that, although both parents could meet the child’s basic needs, high parental conflict, specific incidents (e.g., respondent’s reported out‑of‑state trip with the child and refusal to cooperate with the GAL), and the child’s special needs (autism spectrum, therapy requirements) justified limiting respondent’s parenting time and vesting decision‑making authority in petitioner. The court applied the statutory best‑interest factors, relied on psychologist and GAL reports, and its credibility findings—reviewed for abuse of discretion—were sustained.
- Property/maintenance: The appellate court found procedural and factual deficiencies: the trial court omitted consideration of at least one marital asset, did not adjudicate competing dissipation claims (both parties alleged dissipation, with large sums claimed), and relied on outdated income data for maintenance—necessitating remand so the court can address asset classification, resolve dissipation, and reassess maintenance in light of corrected asset and income findings.

5. Practice implications for family law attorneys
- Preserve and document dissipation claims; litigate classification issues and ensure the trial court adjudicates dissipation before final distribution.
- Put all marital assets on the record with valuations and traceability; watch for judicial omissions that can trigger remand.
- For maintenance, submit current, corroborated income evidence (tax returns, paystubs, expert forecasts) rather than stale data.
- In high‑conflict custody cases, contemporaneous documentation of parental conduct, expert custody evaluations, and GAL testimony are critical—particularly where the child has special needs.
- Obtain express findings on statutory best‑interest factors and credibility determinations to survive abuse‑of‑discretion review.

(Decision is Rule 23, non‑precedential; remand limited to property/maintenance matters.)