In re Marriage of Dribben, 2021 IL App (5th) 200278-U

1. Case citation and parties
- In re Marriage of Dribben, 2021 IL App (5th) 200278‑U (Ill. App. Ct., 5th Dist. Sept. 10, 2021) (Rule 23 order; non‑precedential).
- Petitioner‑Appellant: Wendy Dribben. Respondent‑Appellee: William R. Dribben. Appeal from St. Clair County circuit court.

2. Key legal issues
- Whether an Illinois court retained subject‑matter jurisdiction to enforce/post‑majority educational support and other child‑support related obligations after the parties filed a consent judgment in Missouri.
- Application of the Uniform Interstate Family Support Act (UIFSA), specifically 750 ILCS 22/205(c) (continuing and exclusive jurisdiction), and effect of an out‑of‑state modification on the original Illinois order.
- Whether res judicata or registration of foreign judgments affected enforcement rights.

3. Holding/outcome
- Affirmed. The Illinois trial court correctly dismissed petitioner’s petitions (rule to show cause, contempt, sanctions, and to enforce postmajority educational support/expenses) for lack of subject‑matter jurisdiction because the Missouri consent judgment modified the original Illinois dissolution order as to child‑support matters. The Illinois court retained jurisdiction only over issues not addressed by the Missouri consent judgment (retirement obligation, attorney fees, funeral expenses).

4. Significant legal reasoning
- UIFSA §205(c) bars an original tribunal from exercising continuing, exclusive jurisdiction when another state has issued a child‑support order that modifies the original order.
- The parties’ November 9, 2018 Missouri consent judgment (filed to resolve a Missouri motion to modify) expressly treated the Illinois judgment as if entered in Missouri, acknowledged facts about residential custody and prior payments, and altered child‑support obligations (terminating support from 12/31/2017 forward and stating non‑modifiability for that period while preserving certain expense obligations). Those provisions amounted to a modification of the 2011 Illinois judgment.
- Because Missouri issued the modifying order, enforcement and modification authority over the modified provisions rested with Missouri, not Illinois. Accordingly Illinois lacked subject‑matter jurisdiction to enforce those altered provisions. The court also noted procedural nuances about registration/garnishment but rested the decision on UIFSA jurisdictional principles.

5. Practice implications
- Consent judgments entered in another state can divest the original forum of continuing/exclusive UIFSA jurisdiction if they modify child‑support terms—carefully evaluate whether out‑of‑state agreements alter support provisions.
- To enforce an out‑of‑state support order, follow UIFSA registration/domestication procedures; garnishments may be quashed if steps aren’t followed.
- Preserve claims not addressed in the foreign consent judgment if you want to maintain jurisdiction in the original forum.
- Treat Rule 23 orders as non‑precedential; nonetheless, this decision is a useful reminder to coordinate modification/enforcement strategy between jurisdictions when parties relocate.