In re Marriage of Gregg, 2021 IL App (2d) 210199‑U

1) Case citation and parties
- In re Marriage of Gregg, No. 2‑21‑0199 (Ill. App. Ct., 2d Dist., Sept. 14, 2021) (Rule 23(b) order).
- Petitioner‑Appellee: Robert J. Gregg. Respondent‑Appellant: Hope T. Gregg.

2) Key legal issues
- Whether the trial court abused its discretion by: (a) restricting Hope’s parenting time and ordering reunification therapy; (b) awarding Robert primary residential custody, majority parenting time, and sole decision‑making authority; (c) imputing income to Hope and treating Robert’s restricted stock units as marital property; (d) valuing and awarding the marital residence and classifying certain household items as marital property; and (e) calculating Robert’s income for purposes of maintenance and child support.

3) Holding/outcome
- Court affirmed most of the trial court’s custodial, property and imputation rulings: restrictions on parenting time, requirement of reunification therapy, primary custody and majority parenting time to Robert, sole decision‑making authority to Robert, treatment of RSUs as property, valuation and award of the marital home and certain fixtures to Robert, and imputation of $30,000 income to Hope.
- Reversed and remanded limitedly: trial court abused its discretion in not considering Robert’s stipulated total 2020 gross salary when determining his income; maintenance and child support determinations remanded for recalculation.

4) Significant legal reasoning (concise)
- Custody/parenting time: the appellate court found the GAL’s testimony and the children’s therapists supported the trial court’s findings that unsupervised or expanded contact with Hope would be emotionally harmful (notably to daughter D), justifying supervised visits, reunification therapy, and awarding primary custody and decision‑making to Robert. The court emphasized trial court discretion in weighing credibility and child‑safety evidence.
- Property and income: trial court acted within discretion treating RSUs as marital property and imputing income to Hope based on evidence.
- Error on income calculation: however, the court found reversible error where the trial court failed to consider a stipulated 2020 gross salary for Robert when fixing his income — a material omission affecting maintenance and child support computations.

5) Practice implications for family law attorneys
- GAL/therapist reports and child testimony carry substantial weight in custody disputes—document behavioral harms and therapy recommendations thoroughly.
- When arguing for/against supervised visitation or reunification therapy, furnish clear expert/therapeutic evidence tying parental conduct to child harm.
- Preserve and clearly present income evidence (including stipulated salaries, bonuses, RSUs). Trial courts must consider stipulated earnings when computing income for maintenance/child support — failure risks reversal.
- Provide detailed valuation and classification proof for stock awards and household items; courts will treat RSUs as marital property if supported.
- Expect appellate deference on credibility and custody findings but not on legal/computational errors (e.g., income calculation).