In re Marriage of Beaulieu, 2019 IL App (2d) 171010-U

1. Case citation and parties
- In re Marriage of Beaulieu, 2019 IL App (2d) 171010-U (Ill. App. Ct. 2d Dist. Feb. 4, 2019) (Rule 23 order; non-precedential).
- Petitioner-Appellee: David A. Beaulieu. Respondent-Appellant: Michelle Beaulieu.

2. Key legal issues
- Whether the trial court abused its discretion in modifying (reducing and extending) rehabilitative maintenance.
- Whether the trial court improperly deviated downward from the child-support guidelines and applied reductions not authorized by section 505 of the Illinois Marriage and Dissolution of Marriage Act (750 ILCS 5/505).

3. Holding/outcome
- Affirmed. The appellate court held the trial court did not abuse its discretion in reducing and extending rehabilitative maintenance and properly considered statutory factors. Michelle forfeited her challenge to the child-support deviation because she failed to raise the issue below; the support modification was otherwise affirmed (child support reduced for emancipated child; $800 ordered for remaining minor).

4. Significant legal reasoning (concise)
- Standard of review: abuse of discretion (maintenance/modification). The trial court properly applied the statutory factors in sections 504(a), 510(a‑5), and 513 (considering length of marriage, the parties’ respective incomes and earning capacities, health, lifestyle, and rehabilitative potential).
- Facts supporting modification: since dissolution David’s income increased substantially (≈$347,000 in 2016); Michelle had worked only part‑time (≈10–15 hrs/wk) before her 2016 breast‑cancer diagnosis and had intermittent work history. Although the court acknowledged Michelle’s medical treatment temporarily limited employment, it found her health improving and that she had employable skills; it therefore imputed $25,000 annual income and concluded full prior maintenance was not justified. The trial court reduced rehabilitative maintenance from earlier amounts to $5,600/month plus 20% of David’s net income above $335,000 (capped at $400,000) and set a review date (Nov. 1, 2020).
- Child-support challenge: appellate court dismissed substantive challenge because Michelle did not present the objection at trial (forfeiture).

5. Practice implications for counsel
- Preservation: raise and develop any challenge to guideline deviations at trial—failure to do so will forfeit appellate review.
- Build the record on income imputation and rehabilitative efforts: show concrete job searches, business plans, employer contacts, and medical evidence tying incapacity to specific timeframes if seeking continued or increased rehabilitative maintenance.
- When negotiating or litigating maintenance, consider structuring awards with clear review dates, caps, and triggers; courts will weigh change in payor’s income and recipient’s improving health/part‑time work in modification motions.
- Remember this is a Rule 23 order (non‑precedential), but it reinforces trial courts’ broad discretion in maintenance modifications and the importance of a detailed record.