In re Marriage of Conklin
Court: Illinois Appellate Court | Published: 6/12/2025
Marriage
Quick Summary:
<h3>Case Summary: In re Marriage of Conklin</h3>
<strong>Case Details:</strong>
Order Filed: June 12, 2025
Appellate Court: Illinois, Third District
Appellate Case No.: 3-24-0330
Circuit Case...
Full Case Summary
Case Summary: In re Marriage of Conklin
Case Details: Order Filed: June 12, 2025 Appellate Court: Illinois, Third District Appellate Case No.: 3-24-0330 Circuit Case No.: 11-D-2135 Judge: Honorable Alexander F. McGimpsey III Parties Involved: Petitioner: Carolyn M. Conklin (now Carolyn M. Elbrecht) Respondent: Edward K. Conklin Background: Carolyn and Edward were married in 1988 and divorced in 2012. Their marital settlement mandated maintenance payments of $6,250 per month plus 45% of income exceeding Edward's base pay of $201,272. A modification was made in 2018, establishing a new maintenance amount of $5,917 per month based on a base salary of $250,000 and 30% of additional income. Modification of Maintenance Petition: Edward filed a petition to modify maintenance in March 2020, arguing that Carolyn had not made good faith efforts to become self-supporting after their children were emancipated. He contended that the uncapped nature of the maintenance order provided Carolyn an undue advantage. Key Judgment: The court upheld the decision that no substantial change in circumstances existed to warrant a modification of maintenance. Edward's attempts to terminate or reduce support were denied, as the court found that the increases in his income were foreseeable and anticipated per prior agreements. Testimonies from both parties indicated that income from McDonald's stock options, which Edward exercised, was expected and fell under the calculations defined in the March 2, 2018 order. Court's Findings: The court noted that although Edward's income spiked to $2,130,000 in 2021, this increase was primarily due to exercising stock options earned before the modification agreement, thus not representing a substantial change. The court deemed both parties credible regarding their claims, and discrepancies in income figures presented were considered minor. Edward's assertion of confusion regarding his maintenance obligations was countered by his admissions of payment on bonuses and stock options. Legal Analysis: The court referred to prior case law indicating that a substantial change in circumstances must be significant and unforeseen. It affirmed that increases in income due to pre-existing agreements do not count as substantial changes. Conclusion: The circuit court ruled that Edward did not demonstrate a substantial change in circumstances justifying a modification of maintenance. The judgment of the circuit court is affirmed, denying Edward's appeal.Ask AI About This Case
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