In re Marriage of Blume, 2016 IL App (3d) 140276

1. Case citation and parties
In re Marriage of Blume, 2016 IL App (3d) 140276. Petitioner-Appellee: Tami Blume. Respondent-Appellant: Brad Blume. Judgment affirmed (3rd Dist. July 22, 2016).

2. Key legal issues
- Whether the trial court erred by (a) setting child support at $600/month (below statutory guideline calculations), (b) imputing income to the husband for independent farming in addition to his farmhand wages and in-kind employment benefits, and (c) awarding $2,000/month rehabilitative maintenance as excessive.

3. Holding/outcome
The appellate court affirmed. It found no abuse of discretion in the trial court’s child support, income-imputation, and maintenance determinations.

4. Significant legal reasoning (condensed)
- Standard of review: abuse of discretion for support and maintenance awards.
- Imputation of income: The trial court found Brad voluntarily ceased independent farming, offered no credible reason for stopping, and made “absolutely no effort” to resume. Based on past farming earnings (> $70,000/yr), the court properly imputed farming income for maintenance calculations. The appellate court deferred to the trial court’s credibility findings.
- In-kind employment benefits: The trial court valued the husband’s employer-provided housing/utilities and vehicle at $1,500/month ($18,000/yr) in addition to his $42,000 salary; the appellate court accepted this valuation as within discretion.
- Child support: Although appellate calculations could have yielded higher guideline amounts if imputations had been applied to child support, the trial court noted the parties’ earlier agreement and contemporaneous circumstances (child near emancipation) and set child support at $600/mo. The wife did not appeal the child support amount; the court’s discretion and deference to its factual findings supported affirmation.
- Maintenance: Rehabilitative maintenance (not in gross) was appropriate because the wife had taken steps toward nursing credentials and needed training to restore her standard of living. The $2,000/month award, reviewable after three years, was supported by the parties’ income disparity and the wife’s retraining timeline.

5. Practice implications for attorneys
- Courts will impute income for voluntarily foregone self-employment when credible evidence shows prior earnings and lack of legitimate reason to stop; preserve cross-examination and documentary proof of efforts to farm (or reasons not to).
- Document and quantify in-kind employment benefits (housing, vehicle, utilities); they can be added to gross income for support/maintenance.
- Child support decisions may reflect party agreement and overall equitable outcomes (maintenance interplay); challenge or preserve objections if you want appellate review.
- For maintenance claims, present concrete retraining plans, timelines, and cost projections to justify rehabilitative awards and duration.