In re Marriage of Huffman, 2023 IL App (4th) 220531-U

1. Case citation and parties
- In re Marriage of Huffman, No. 4-22-0531, 2023 IL App (4th) 220531-U (Ill. App. Ct. 4th Dist. June 14, 2023) (Rule 23 order).
- Petitioner-Appellant: Jeffrey D. Huffman. Respondent-Appellee: Cathy L. Huffman.

2. Key legal issues
- Whether the trial court lawfully deviated from the statutory child support guidelines without making the written findings required by the Illinois Marriage and Dissolution of Marriage Act (750 ILCS 5/505(a)(2), (3.4)).
- Whether the court’s docket entry and factual recitation satisfied the Act’s mandatory specificity (including stating the presumed guideline amount) when it denied/declined to order child support.

3. Holding/outcome
- The Fourth District vacated the trial court’s denial of child support and remanded for entry of proper written findings. The appellate court concluded the trial court failed to state the presumptive guideline support amount and the statutorily required reasons for any deviation.

4. Significant legal reasoning
- The court emphasized the mandatory nature of the Act’s written-finding requirements: when a court departs from the guideline calculation it must state the presumed support amount and explain the basis for deviation in writing.
- Although the trial judge had presided over the lengthy, contentious dissolution and entered factual findings about incomes, parenting time and the parties’ conduct, the docket entry did not include a calculation of the presumptive support amount or the statutorily required specific findings explaining any deviation. Mere narrative descriptions of the parties’ conflict, credibility assessments, or income recitations do not satisfy the statute.
- Because the statutory requirements are specific and mandatory, failing to identify the guideline figure and explain departure requires vacatur and remand rather than deference to the court’s overall knowledge of the case.

5. Practice implications (concise)
- When seeking or defending departures from Illinois guideline child support, always (a) prepare and offer a completed support worksheet showing the presumptive amount; (b) submit proposed written findings tying each deviation to statutory factors; and (c) request the court to state on the record and in writing the presumptive figure and precise reasons for any variance.
- Preserve the record (transcripts, exhibits, paystubs, parenting-time percentages) so the court can and will set forth the necessary calculations.
- If a trial court fails to make the required findings, move for clarification or reconsideration and, if necessary, appeal—failure to make the statutory findings will result in vacatur and remand.
- Note: this is a Rule 23 (non‑precedential) decision; persuasive but not binding beyond its limited scope.