In re Marriage of Taylor C., 2025 IL App (4th) 250061‑U

1) Case citation and parties
- In re Marriage of Taylor C., No. 4‑25‑0061 (Ill. App. Ct., 4th Dist., July 29, 2025) (Rule 23 order; non‑precedential).
- Petitioner‑Appellant: Taylor C. (mother); Respondent‑Appellee: Joel V. (father).

2) Key legal issues
- Whether the trial court’s denial of mother’s petition to relocate the parties’ two children from Macomb, IL, to Greenville, SC comported with the best‑interest analysis and statutory factors in 750 ILCS 5/609.2(g).
- Whether the trial court’s factual findings on the 609.2(g) factors were against the manifest weight of the evidence.

3) Holding/outcome
- The Fourth District affirmed. The appellate court held the trial court did not err in denying the relocation; its findings and ultimate best‑interest determination were not against the manifest weight of the evidence.

4) Significant legal reasoning (concise)
- Standard of review: appellate deference to the trial court’s factual findings and credibility determinations under the manifest‑weight standard.
- The trial court conducted the multi‑factor 609.2(g) analysis (children’s needs, parent‑child relationships, motives, proposed parenting plan, distance and travel burdens, stability/supports at proposed site, etc.) and found relocation not in the children’s best interests.
- The record supported conclusions that: the children were generally doing well and had a strong, close relationship with father and paternal family in central Illinois; remote contact could not substitute for regular in‑person contact; mother had unilaterally changed schooling (homeschooling) without court modification; proposed parenting schedule would materially change the regularity and character of father‑child contact (longer, less frequent visits); and questions about the new household’s stability and the relocating family’s motives and logistics were relevant.
- The appellate court emphasized that the trial court was entitled to weigh competing testimony (including credibility of mother, stepfather’s employment history and family background) and to conclude the relocation’s asserted benefits did not outweigh the harm to established parent‑child contact.

5) Practice implications for family law practitioners
- Relocation petitions must comprehensively address every 609.2(g) factor with admissible, specific evidence: objective comparative school data, concrete community supports, housing/employment stability, travel logistics and costs, and a parenting plan that preserves frequent, meaningful in‑person contact (not merely extended but infrequent summer visits).
- Anticipate and rebut credibility attacks: document cooperation history, prior notice/compliance with parenting‑plan modification obligations (e.g., prior homeschooling decisions), and contemporaneous communications about children’s welfare.
- Where relocation will reduce regular contact, propose realistic, detailed transport/expense arrangements and a transitional plan to mitigate harm. Trial courts’ credibility findings are difficult to overturn on appeal.