In re Marriage of Tiffany A., 2025 IL App (5th) 250409‑U

1) Case citation and parties
- In re Marriage of Tiffany A., No. 5‑25‑0409 (Ill. App. Ct., 5th Dist.), decision filed Oct. 14, 2025 (Rule 23 non‑precedential).
- Petitioner‑Appellant: Tiffany A. / Respondent‑Appellee: David A. Presiding Justice McHaney; Justices Moore & Vaughan concurred.

2) Key legal issues
- Whether the guardian ad litem’s (GAL) investigation/report was inadequate such that the trial court improperly relied on it.
- Whether the trial court’s allocation of a majority of parenting time to the father was against the manifest weight of the evidence under the statutory “best interest of the child” factors (750 ILCS 5/602.5, 602.7).

3) Holding/outcome
- Affirmed. The appellate court held the GAL’s report was adequate and thorough, and the trial court’s award of majority parenting time to David was not against the manifest weight of the evidence. The trial court’s joint decision‑making order for education, health, religion, and extracurricular activities was left intact (Tiffany did not appeal that ruling).

4) Significant legal reasoning
- GAL adequacy: The GAL interviewed both parents, the children, and third parties (a friend and an ex‑girlfriend of David), analyzed the statutory best‑interest factors, and made specific parenting‑time recommendations. The appellate court found that process adequate.
- Manifest‑weight review: The court applied the deferential standard and found the trial court’s factual findings supported by evidence: father’s involvement in parenting (including pre‑dissolution caregiving and extracurricular coaching), stability of residence in Mendon with family support, proximity to a local school, ongoing treatment for PTSD, limited recent alcohol use, and efforts to address mental‑health issues. Countervailing evidence included incidents recounted by Tiffany (allegations of controlling behavior, an order of protection, school attendance/behavior issues for the children, a DCFS investigation arising from allegations involving a third party), which the trial court weighed and found insufficient to award primary parenting time to Tiffany. The GAL’s analysis of factors in 602.5/602.7 was central to the court’s factfinding.

5) Practice implications
- Challenges to a GAL report are uphill: appellate courts look for thoroughness (who was interviewed, what inquiries were made, and whether statutory factors were addressed). Preserve specific trial‑level objections and develop contrary evidence.
- Build a full evidentiary record on statutory factors (parental fitness, stability, continuity of schooling, child behavior/therapy, third‑party allegations, substance/mental‑health treatment).
- Temporary orders, unilateral moves, and documentation of parenting responsibility (attendance at school, medical care, extracurriculars) are critical.
- GAL costs may be split; consider cost allocation motions.
- Remember Rule 23 status: this opinion is non‑precedential except in limited circumstances.