In re Marriage of Keigher, 2023 IL App (1st) 221103-U

1) Case citation and parties
- In re Marriage of Keigher, No. 1-22-1103, 2023 IL App (1st) 221103-U (Oct. 25, 2023) (Ill. App. Ct., 1st Dist.).
- Petitioner-Appellee: Amy Keigher. Respondent-Appellant: Greg Keigher.

2) Key legal issues
- Whether the trial court’s finding that the father’s conduct “seriously endangered” the children’s health and welfare was against the manifest weight of the evidence.
- Whether the trial court abused its discretion by restricting the father’s parenting time (imposing supervised visitation, limiting electronic contact, awarding mother decisionmaking authority, ordering therapeutic placements).

3) Holding/outcome
- The appellate court affirmed. It held the trial court’s finding of serious endangerment was not against the manifest weight of the evidence and that ordering supervised parenting time and other restrictions was not an abuse of discretion.

4) Significant legal reasoning (concise)
- The appellate court deferred to the trial court’s factual and credibility determinations. The record contained substantial evidence supporting the trial court’s conclusion of serious risk to the children: expert evaluations (Dr. David Finn’s 604.10(b) report), GAL findings, and documented incidents (e.g., older boys binding a younger child with packing tape; an incident where older boys zip-tied and threatened a cousin with an airsoft gun; untreated behavioral problems exacerbated by the father undermining mother’s interventions). Dr. Finn concluded the father engaged in triangulation, coercive/controlling dynamics, and failed to accept responsibility—creating ongoing risk. The court had also limited the father’s contact after evidence of direct electronic communications in violation of prior orders and evidence his relatives were being encouraged to pressure the mother. Although the father produced a counter-report (Dr. Shapiro) with somewhat different recommendations, the appellate court found the trial court reasonably preferred the weight and implications of Dr. Finn’s findings. Given the focus on the children’s health and welfare, the court’s imposition of supervised visitation, geographic and activity restrictions, and temporary award of decisionmaking to the mother fell within its discretionary authority.

5) Practice implications for family law attorneys
- Expert evaluations (604.10) and a GAL report can be dispositive—invest early in thorough, contemporaneous evaluations addressing safety, triangulation, treatment compliance, and specific incidents.
- Meticulously document violations of visitation and communication orders (phone/text screenshots, witness statements, therapist/GAL reports) to support emergency relief or contempt.
- Courts will restrict parenting time where a parent’s conduct undermines treatment, exposes children to dangerous behavior, or engages in coercive/triangulating conduct—even absent physical abuse.
- Be prepared to defend or attack credibility/weight of experts; appellate courts will defer to trial-court determinations.
- Note: opinion filed under Ill. S. Ct. R. 23 (nonprecedential except in limited circumstances).