In re Marriage of Bedolli, 2019 IL App (4th) 180477-U

1. Case citation and parties
- In re Marriage of Bedolli, 2019 IL App (4th) 180477‑U (Ill. App. Ct., 4th Dist. Sept. 5, 2019) (Rule 23 order, non‑precedential).
- Petitioner‑Appellant: Blaine M. Bedolli. Respondent‑Appellee: Leanne Bedolli.

2. Key legal issues
- Whether the trial court erred in denying Blaine’s motion to modify child support and maintenance after a substantial reduction in his income.
- Whether the reduction in income was involuntary or, if voluntary, made in good faith so as to permit downward modification.

3. Holding/outcome
- The Fourth District affirmed: the trial court did not err in denying Blaine’s motion to modify his child support and maintenance obligations.

4. Significant legal reasoning
- The appellate court reviewed the trial court’s factual findings and credibility determinations and concluded they were not against the manifest weight of the evidence. At the modification hearing the court heard competing testimony:
- Company accountant and Blaine’s wife described significant business financial distress (large IRS debt, missed installment agreements, state obligations) and company‑wide payroll reductions instituted to preserve cash flow and avoid company shutdown.
- Blaine testified his compensation dropped from roughly $78–88K (2015–2016) to a $30K salary (no commissions) in mid‑2017 and acknowledged he could seek outside employment but believed pay elsewhere would be similar or lower; he also purchased a second home in Springfield after relocation litigation.
- Leanne alleged the pay cut was voluntary or taken to benefit Blaine’s new wife and criticized Blaine’s post‑dissolution financial choices.
- The trial court was entitled to credit or discredit witnesses and weigh documentary proof (or its absence). The appellate court found the denial of relief was within the court’s discretion given the record and credibility rulings.

5. Practice implications
- Modification based on reduced income requires a clear record showing the reduction was involuntary and/or in good faith. Trial courts give deference to credibility findings and may deny relief where the obligor’s conduct (asset purchases, lack of job‑search effort, family business arrangements) undercuts the claim of involuntariness.
- Practical tips: present contemporaneous payroll records, IRS correspondence, layoff notices, written job‑search evidence, and clear accounting to prove involuntary reduction; anticipate and rebut claims of voluntary impoverishment. Where stipulations govern future modification, highlight their terms and any reservation of rights. On appeal, challenge is difficult absent clear abuse of discretion or findings contrary to the manifest weight of the evidence.