Turner
Key Insights
Affirmance Rate
33%
Reversal Rate
67%
Case History
12 Cases
Case Outcomes
Recent Decisions
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.
In re Marriage of Turner
1. Case citation and parties - In re Marriage of Turner, 2023 IL App (3d) 220398-U (Order filed Mar. 3, 2023) (Sup. Ct. R. 23 — not for precedent). - Petitioner-Appellant: Alexander (Alex) Turner. Respondent-Appellee: Lyndsey Turner. Du Page County circuit court; appeal from parenting allocation after four-day trial in dissolution proceeding. 2. Key legal issues - Whether the appellate court had jurisdiction to review the trial court’s denial of Alex’s May 2021 petition for a temporary parenting schedule. - Admissibility and prejudice analysis for a court‑appointed evaluator’s (Dr. Hatcher) report and testimony. - Whether the trial court erred in permitting the mother to elicit opinion testimony from the father’s retained expert (Dr. Shapiro) on cross‑examination. - Whether the trial court’s allocation of decision‑making authority (mother as primary decision‑maker) and parenting time (majority to mother) was against the manifest weight of the evidence. 3. Holding/outcome - Judgment affirmed in all respects. Appellate court: no jurisdiction to review the temporary petition denial because that specific order was not identified in the notice of appeal; evidentiary rulings and parenting allocations affirmed. 4. Significant legal reasoning - Jurisdiction: An appellant must identify the order appealed in the notice of appeal; because Alex failed to identify the July 2021 order denying a hearing on his temporary petition, the court lacked jurisdiction to review it. - Expert evidence: The trial court did not abuse discretion admitting the court‑appointed evaluator’s report; any claimed prejudice was negated because the trial court expressly disregarded portions it found unreliable. The court also did not err in permitting cross‑examination to elicit opinion testimony from the controlled expert beyond his report — the ruling fell within trial court’s discretion under the circumstances. - Parenting allocation: The manifest‑weight standard governs credibility and fact determinations in custody disputes. The court credited the GAL and court evaluator who found significant parental conflict, Alex’s lack of cooperativeness and concerning personality traits (e.g., evaluator’s narcissistic personality disorder diagnosis), and that Lyndsey was more likely to place the children’s needs first. Those credibility findings and the resulting decision‑making and parenting time allocations were supported by the record and therefore not against the manifest weight of the evidence. 5. Practice implications - Procedural: Identify every order being appealed in the notice of appeal to preserve jurisdiction. - Experts: Challenges to court‑appointed evaluators require careful preservation; trial courts have broad discretion to admit/evaluate such reports and to discount portions. Controlled experts can be probed on cross‑examination; expect courts to permit development of testimony beyond written reports within discretion. - Custody strategy: Trial courts defer to credibility findings and GAL/evaluator recommendations; extensive record demonstrating cooperation, parenting competence, and prioritization of children’s needs is critical when contesting primary decision‑making or parenting time.
In re Adoption of Blake B.
1) Case citation and parties - In re Adoption of Blake B., 2022 IL App (5th) 220154-U (Ill. App. Ct. 5th Dist. July 20, 2022) (Rule 23 order, non‑precedential). - Petitioners/Appellees: Ramona R. & Robert G. (maternal grandmother and her husband). - Respondents/Appellants: Aymara R.B. (mother) and James A.B. (father). Appeal by mother Aymara R.B. 2) Key legal issues - Whether the trial court erred in finding the mother unfit under the Illinois Adoption Act (750 ILCS 50/1(D)) — including grounds of failure to maintain reasonable interest/concern/responsibility, failure to visit/communicate for 12+ months, failure to plan for the child, and habitual drug/alcohol addiction. - Whether terminating parental rights and approving adoption by petitioners was against the child’s best interests. - Whether there were any meritorious issues for appeal (Anders counsel motion). 3) Holding/outcome - Appellate court affirmed. Counsel’s Anders motion granted; counsel allowed to withdraw. The circuit court’s findings of parental unfitness and that adoption by petitioners was in the child’s best interest were upheld. 4) Significant legal reasoning - Standard: parental unfitness must be proved by clear and convincing evidence. The court may find any one statutory ground sufficient. - The record showed virtually no contact between mother and child from Dec. 2016 until after the adoption petition (years of non‑contact, no cards/gifts/support except limited payments), missed/failed supervised visits, failure to engage in offered virtual parenting time, and evidence of drug use (including appearing under the influence during a Zoom visit and recent felony drug charge). Trial testimony established the child’s significant medical/developmental needs (Turner syndrome, speech/occupational therapy, feeding concerns) and the petitioners’ ongoing care and stability. - Applying Syck and other precedents, the court emphasized examining parental efforts rather than success; here the mother’s lack of effort supported unfitness findings. The court also found termination in the child’s best interest given the child’s needs, lack of bond with mother, and stability with petitioners. 5) Practice implications for family attorneys - One statutory ground proved by clear and convincing evidence can sustain an unfitness finding — focus proof on any dispositive statutory element (e.g., 12+ months’ non‑contact). - Document offers of visitation and the parent’s responses; contemporaneous records, GAL testimony, and demonstration of the custodial caregivers’ continuous involvement are persuasive. - Evidence of substance abuse, criminal charges, and impaired parenting episodes (including virtual appearances) is highly probative. - When representing parents on appeal, ensure potential issues meet arguable merit standards under Anders; appellate courts will affirm well‑supported fitness/best‑interest findings and permit withdrawal if no non‑frivolous points exist.
In re Marriage of Lisk
1. Case citation and parties In re Marriage of Lisk, No. 4-20-0031, 2021 IL App (4th) 200031-U (Ill. App. Ct. Mar. 26, 2021) (Rule 23 order). Petitioner-Appellee: Tammy L. Lisk; Respondent-Appellant: Dale W. Lisk; Intervenor-Appellee: Ronald Perrine. (Justice Turner dissented; decision under Rule 23—limited precedential value.) 2. Key legal issues - Proper valuation and division of marital property in a dissolution (whether debts/obligations must be included in the court’s valuation and whether a valuation date was required). - Whether the trial court properly found and remedied dissipation of marital assets. - Admissibility/consequences of deemed admissions from unresponded Requests to Admit. - Validity of an intervenor’s interpleader claim and recovery against the marital estate. 3. Holding/outcome The Fourth District affirmed. The trial court’s valuation and 50/50 distribution (with an equalizing judgment to Tammy) and its finding of dissipation were upheld. The court also affirmed entry of a $20,408 judgment in favor of intervenor Perrine and the ordered process for liquidating equipment at Perrine’s property to satisfy his claim. 4. Significant legal reasoning (summary) - Deemed admissions: Dale failed to timely respond to Requests to Admit, so the trial court properly treated the attached appraisals, sale records, and stated values as admitted—these admissions supported the court’s valuation and findings. - Dissipation: The court relied on extensive factual findings (mortgage nonpayment, serious disrepair, animal movements/sales, prior contempt findings) to conclude Dale dissipated marital assets; the appellate court deferred to the trial court’s factual conclusions and equitable division. - Valuation/debts/date: The appellate court rejected Dale’s contention that the trial court’s valuation was erroneous for failing to subtract debts or set a formal valuation date, finding the evidence before the court supported the valuation and distribution scheme. Trial-court discretion in asset division and factual findings reviewed for abuse/manifest-weight; none found. - Interpleader/third-party claim: Perrine’s claim for costs to care for abandoned cattle was properly resolved against the marital estate; the trial court’s ordering of sale proceeds allocation (pay Perrine, then apply remaining proceeds to Tammy’s equalizing judgment) was permissible. 5. Practice implications for family-law attorneys - Respond to Requests to Admit promptly—failure can be dispositive and supply critical valuation evidence. - Vigorous compliance with discovery is essential: repeated noncompliance risks contempt, deemed admissions, and unfavorable factual findings. - Document dissipation early (records of sales, transfers, failures to maintain property); move quickly for relief (contempt, injunctive relief, temporary orders). - When third parties claim rights to marital assets, consider interpleader or assert third-party claims early; trial courts can order liquidation and priority allocation. - Appellate review is deferential on factual valuation and discretionary divisions—develop a robust evidentiary record at trial.
Other 4th District Judges
Frequently Asked Questions
What is Turner's overall affirm rate on family law appeals?
Turner has an overall affirm rate of 33% across 12 family law cases reviewed.
Which Illinois appellate district does Turner serve in?
Turner serves in the Illinois 4th District Appellate Court.
How often are Turner's decisions reversed on appeal?
Turner has a 67% reversal rate, with 8 decisions reversed out of 12 total cases.
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