In re Marriage of Lamb

Full Case Summary

Case Summary: In re Marriage of Rachel L. Lamb

Background

Rachel and Thad L. Lamb divorced in October 2017 under the Illinois Marriage and Dissolution of Marriage Act, with a marital settlement agreement (MSA) stipulating no child support due to equal parenting responsibilities for their two children. Rachel later filed for child support in February 2023, which was granted by the trial court in August 2024.

Legal Framework

Child support provisions may be modified under Section 510(a)(1) of the Illinois Marriage and Dissolution of Marriage Act, contingent upon proof of a substantial change in circumstances. The party seeking modification bears the burden of proof to identify such changes.

Trial Court's Ruling

The trial court granted Rachel's petition for child support, concluding that Thad's financial circumstances had significantly improved since their original divorce, despite his objections regarding the evidentiary support for this modification.

Appellate Court Findings

The Appellate Court disagreed with the trial court's conclusion, identifying a lack of evidence demonstrating a substantial change in Thad's financial situation since the decree. The court emphasized the absence of new evidence about his income adjustments, pointing out that Rachel was aware of Thad's compensation structure, including bonuses and rebates, prior to filing her petition. Consequently, the appellate court reversed the trial court’s decision, determining that the ruling was against the manifest weight of the evidence.

Child Support Order Details

As part of the original MSA, the couple agreed to equal custody, with Thad responsible for maintaining health insurance for the children, while sharing medical, educational, and childcare costs.

Conclusion

The appellate court's reversal underscores the critical necessity of clear and substantial evidence to support claims for modifying child support agreements. This ruling reinforces adherence to existing decrees in the absence of demonstrable financial shifts since their establishment.

Note: This order is filed under Supreme Court Rule 23 and serves as non-precedential except under specific circumstances as allowed under Rule 23(e)(1).