In re Marriage of Charles Y., 2022 IL App (4th) 210731-U

1. Case citation and parties
- In re Marriage of Charles Y., 2022 IL App (4th) 210731‑U.
- Petitioner‑Appellant: Charles Y.; Respondent‑Appellee: Kassandra Y.; child: K.M.Y. (b. Oct. 2015).

2. Key legal issues
- Allocation of parenting time (which parent receives the majority of time).
- Allocation of parental decision‑making responsibilities (primary vs. joint) for education, health, extracurricular activities, and religion.
- Whether the trial court’s allocations were against the manifest weight of the evidence.

3. Holding/outcome
- Affirmed. The Fourth District held the trial court’s allocation of majority parenting time to Kassandra and primary decision‑making to her for education and health (with joint decision‑making for extracurriculars and religion) was not against the manifest weight of the evidence.

4. Significant legal reasoning
- Standard of review: allocations implicating parental responsibilities and parenting time are reviewed for manifest weight of the evidence; appellate courts defer to trial courts’ credibility determinations and factual findings.
- The trial court issued a detailed factual recitation after a two‑day hearing and credited evidence supporting Kassandra’s primary caretaking and stability. The court considered: each parent’s work schedules, day‑to‑day caretaking (baths, laundry, medical administration, school involvement), daycare/school history, incidents between the parties (temporary order of protection filings, alleged withholding of contact June–Sept 2020, an untimely exchange because of COVID concern, DCFS investigation found unfounded), and unilateral choices (Charles enrolling the child in play therapy without prior consultation).
- Appellant’s arguments—he traveled for performances, was more willing to foster the parent–child relationship, and the trial court misconstrued primary caretaking—were rejected because the record did not compel a different factual finding; the trial court’s credibility findings and evaluation of the parties’ conduct carried dispositive weight.

5. Practice implications
- Trial courts’ credibility determinations and detailed factual findings are highly persuasive on appeal; manifest‑weight review is difficult to overcome.
- Preserve and document: (a) day‑to‑day caregiving activities, (b) work schedules and travel frequency, (c) communications and exchange histories (use court‑friendly platforms like TalkingParents), (d) any interference or withholding of contact, and (e) reasons for unilateral decisions (medical/therapy).
- When seeking primary decision‑making or majority time, present clear, contemporaneous evidence of caretaking, stability, and parental availability. Conversely, if opposing, challenge credibility, show instability or unilateral conduct harmful to co‑parenting.
- Beware procedural/briefing pitfalls (Rule 341 issues noted by appellee); appellate courts may be less receptive to inadequately supported arguments.
- Note: this is a Rule 23 order — persuasive but non‑precedential.