In re Marriage of Jessica F., 2024 IL App (4th) 231264

1. Case citation and parties
- In re Marriage of Jessica F., n/k/a Jessica S. (Petitioner-Appellee) v. Justin H. (Respondent-Appellant), 2024 IL App (4th) 231264 (4th Dist. May 15, 2024). Trial court judgment granting petitioner’s modification of the parenting plan affirmed.

2. Key legal issues
- Whether the trial court properly modified an existing, nonstandard parenting plan to a “standard” parenting plan under the child’s best‑interests standard and based on changed circumstances.
- Whether the trial court abused its discretion by reserving ruling on respondent’s motion for an in camera interview of the child.
- Whether the court erred in calculating and reallocating parenting time (respondent argued his time was substantially reduced).

3. Holding / outcome
- Appellate court affirmed. The trial court’s modification of the parenting plan was upheld; the court’s reservation of ruling on an in camera interview was not an abuse of discretion; the parenting‑time allocation/calc was within the trial court’s discretion and was not erroneous.

4. Significant legal reasoning (summary)
- Deference to trial court fact‑finding and credibility determinations: the appellate court emphasized that evaluation of witness credibility, weighing of evidence, and assessment of the child’s best interests are matters for the trial court and will not be reversed absent an abuse of discretion.
- Changed circumstances and best interests: the record supported the mother’s move to Rushville for smaller schools and the children’s welfare (including bullying concerns), and the mother had been the child’s primary caregiver since birth. The trial court reasonably found modification practical and in the child’s best interests (continuity of primary caregiving, sibling relationships, school stability).
- In camera interview procedure: the trial court’s practice of reserving an in camera interview until after presentation of evidence was a valid exercise of discretion; appellant failed to show prejudice or that the reservation constituted an abuse.
- Parenting‑time calculation: the reallocation fell within the trial court’s authority to structure time based on best‑interest findings; mere reduction in respondent’s time, without a showing of miscalculation or legal error, did not mandate reversal.

5. Practice implications (concise)
- Custody/modification appeals will survive if trial court’s factual findings and credibility calls are supported by evidence—build a thorough evidentiary record at trial (school records, disciplinary reports, witnesses about bullying, parenting practices, living arrangements).
- If seeking an in camera interview, move timely and articulate specific necessity; preserve any objection and establish prejudice if the court defers.
- When contesting a relocation or parenting‑time change, address motive for move, alternative schooling, and compensatory parenting time with concrete scheduling proposals and evidentiary support.
- Expect appellate deference on discretionary custody determinations; preserve arguments showing clear legal error or prejudicial abuse of discretion for reversal.