Walker
Key Insights
Reversal Rate
100%
Case History
3 Cases
Case Outcomes
Recent Decisions
In re Marriage of Walker
1. Case citation and parties - In re Marriage of Walker, 2019 IL App (3d) 180575-U (Ill. App. Ct., 3d Dist. Dec. 20, 2019) (Rule 23 order; non‑precedential). - Petitioner‑Appellant: Daniel R. Walker. Respondent‑Appellee: Kristin L. Walker n/k/a Kristin L. Bannon. 2. Key legal issues - Whether the trial court abused its discretion in modifying child support under a marital settlement agreement (MSA) that provided for a reduction once the children were “enrolled in a full time course of education.” - Whether the MSA’s reduction formula was an unenforceable downward deviation from the Illinois Child Support Act. - Whether the trial court properly applied the post‑dissolution statutory child‑support scheme (amended 750 ILCS 5/505, effective July 1, 2017) when recalculating support. 3. Holding/outcome - Affirmed. The trial court did not abuse its discretion in finding a substantial change in circumstances and reducing respondent’s child support obligation from $800 to $443 per month. 4. Significant legal reasoning - Standard of review: child‑support modification rests within the trial court’s wide discretion and will be overturned only for abuse of that discretion. - Trial findings: the court found respondent credible, petitioner not; it found the MSA’s trigger (children enrolled in full‑time education) occurred because the children no longer required daytime care by petitioner. That factual finding supported a substantial‑change determination under 750 ILCS 5/510(a)(1). - The court rejected petitioner’s contention that the original support amount was an unlawful downward deviation because no evidence proved it. Given the parties’ agreement that support was modifiable on the stated trigger, the court treated the MSA as enforceable. - Because the statutory child‑support law had been amended, the trial court applied the current statutory framework (July 1, 2017 amendment to section 505) in calculating the new obligation, concluding the parties’ MSA result was essentially aligned with the new formula. The court considered earnings, LLC distributions and gifts to respondent, and petitioner’s SSDI in computing support. 5. Practice implications (concise) - Draft MSAs with clear, enforceable modification triggers and address whether modifications should be calculated under then‑existing or future statutory formulas. - Anticipate that courts may apply current statutory guidelines when a contracted trigger occurs; include language specifying intent regarding later statutory changes. - When litigating modification, present concrete evidence of income (salary, K‑1 distributions, gifts) and custody/parenting‑time facts; credibility and detailed financial proofs are critical. - Remember Rule 23 status: this opinion is non‑precedential but instructive on how Illinois courts treat MSA modification clauses and post‑dissolution statutory changes.
In re Marriage of Greer
- Case citation and parties In re Marriage of Greer, No. 1-16-2885, 2019 IL App (1st) 162885‑U (Apr. 25, 2019) (Ill. App. Ct., 1st Dist., Rule 23 order). Petitioner-Appellee: Maurissa Greer. Respondent-Appellant: Anthony Walker. - Key legal issues 1) Whether the trial court was required to make the specific findings mandated by amended 750 ILCS 5/504 when awarding maintenance. 2) Whether the trial court abused its discretion in setting maintenance at $600/month for 24 months. - Holding/outcome Affirmed. The appellate court upheld the trial court’s maintenance award of $600 per month for 24 months. - Significant legal reasoning (concise) - Applicable law: The court determined the version of the Marriage and Dissolution of Marriage Act that became effective January 1, 2016 (which added the subsection requiring “specific findings of fact” for maintenance awards—see 750 ILCS 5/504(b‑2)) applied because the dissolution judgment was entered after that effective date and section 801(b) makes the new Act govern pending actions where no judgment had been entered. - Record inadequacy: The core reason for affirmance was procedural — the appellant failed to provide an adequate record for review. There was no court‑reporter transcript or bystander’s report of the dissolution hearing, so the appellate court could not evaluate whether the trial court made the statutorily required findings or abused its discretion. The appellant bears the burden to present a sufficient record to demonstrate error; absent a transcript or agreed statement of facts, appellate review is necessarily limited and reversible error cannot be presumed. The opinion cites precedent that where the basis for maintenance is established in the record explicit findings may not be mandatory, but under the amended statute the requirement exists — nonetheless appellant’s failure to preserve the record was dispositive. - Practice implications (bullet points) - Always preserve a complete record when litigating maintenance: secure a court reporter for hearings, or prepare an agreed statement of facts if no reporter is available. - After the 2016 amendments to §504, request specific written findings of fact (or make a posttrial motion) when maintenance is contested to satisfy the statutory requirement and to preserve issues for appeal. - Ensure detailed financial disclosures and exhibits are admitted and appear in the record; without them an appellant cannot demonstrate abuse of discretion. - Note: this is a Rule 23 (non‑precedential) order; persuasive but not binding precedent.
Other 1st District Judges
Frequently Asked Questions
What is Walker's overall affirm rate on family law appeals?
Walker has an overall affirm rate of 0% across 3 family law cases reviewed.
Which Illinois appellate district does Walker serve in?
Walker serves in the Illinois 1st District Appellate Court.
How often are Walker's decisions reversed on appeal?
Walker has a 100% reversal rate, with 3 decisions reversed out of 3 total cases.
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