In re Marriage of Turner

1. Case citation and parties
- In re Marriage of Turner, 2025 IL App (3d) 250246-U (Ill. App. Ct., 3d Dist. Oct. 8, 2025) (Rule 23 order; non‑precedential).
- Petitioner‑Appellant: Alexander Turner. Respondent‑Appellee: Lyndsey Turner. Appeal from Du Page County (18th Jud. Cir.), Judge Neal W. Cerne.

2. Key legal issues
- Whether the trial court’s allocation of decision‑making authority and parenting time (entry of the September 6, 2022 allocation judgment) was against the manifest weight of the evidence.
- Whether the court abused its discretion in denying Alex’s petition to modify that allocation.
- Whether the trial court erred in admitting/considering the allocation evaluator’s psychological report/diagnosis (alleged diagnosis of Narcissistic Personality Disorder) and in its evidentiary rulings regarding expert testimony and Rule 213(f) disclosures.

3. Holding / outcome
- Affirmed. The appellate court held the trial court’s best‑interest findings were not against the manifest weight of the evidence, the denial of the petition to modify was not an abuse of discretion, and the trial court’s evidentiary rulings did not prejudice Alex.

4. Significant legal reasoning
- Standard of review: allocation findings reviewed for manifest weight; evidentiary/discovery rulings and modification decisions reviewed for abuse of discretion.
- The court emphasized substance over label: both experts (Dr. Roger Hatcher, the section 604.10 evaluator, and Dr. Robert Shapiro, Alex’s expert) and the GAL agreed Alex displayed marked narcissistic traits and self‑centered, controlling behavior. The court found it immaterial whether the evaluator’s use of the formal NPD label was clinically pristine—what mattered was the observed behaviors and their likely impact on the children.
- The GAL and evaluator tied those characteristics directly to several statutory best‑interest factors (parental ability to cooperate, empathy, willingness to put children’s needs first), supporting awarding Lyndsey sole decision‑making responsibility and majority parenting time.
- The court rejected arguments that admission of the evaluator’s report or use of expert testimony was unduly prejudicial or procedurally fatal under Rule 213(f), finding no abuse in allowing the evidence or the deposition/testimony presented.

5. Practice implications (concise)
- In allocation disputes, courts will focus on demonstrable parenting behavior and functional impact on best‑interest factors rather than debate over diagnostic semantics.
- Section 604.10 evaluations that include psychological testing and forceful characterizations (e.g., NPD) can be admissible and persuasive even if challenged; to exclude such evidence, a party must show real methodological/prejudice defects, not just label dispute.
- GAL concurrence with an evaluator’s behavioral findings is influential.
- Failure to obtain perfect expert disclosure under Rule 213 may not automatically bar testimony or deposition use; sanctions/disallowance remain discretionary—contest strategically and tie any prejudice to specific trial fairness harms.
- Appellate review is deferential (manifest‑weight/abuse‑of‑discretion): develop a strong factual record and target concrete errors.