In re Marriage of Lebovich, 2025 IL App (1st) 230576-U
Divorce Judgment Affirmed Despite Bias Claims
Illinois appellate court affirmed trial court's comprehensive divorce judgment, rejecting judicial bias claims and upholding parenting restrictions, electronic device access requirements, dissipation findings, and $200,000 attorney fee award. Courts apply best-interests standard for parenting decisions. Attorneys should draft specific electronic access provisions and document economic justifications for declining benefits.
Facts
Alissa and Lenny Lebovich divorced with disputes over parenting time, children's electronic device access, extracurricular activities, and attorney fees. The trial court issued comprehensive orders limiting activities, requiring electronic access, finding asset dissipation, and awarding $200,000 in attorney fees. Lenny appealed claiming judicial bias.
Issue
Whether the trial judge exhibited bias warranting reversal and whether the parenting, dissipation, and fee determinations were proper.
Holding
The appellate court rejected all bias claims and affirmed the trial court's orders. The parenting restrictions, electronic device access requirements, dissipation findings, and attorney fee award were all supported by the record and proper legal standards.
Key Reasoning
- Judicial bias requires objective evidence of partiality, which was not established in the record
- Best-interests analysis supported restricting extracurricular activities based on expert testimony about overscheduling and fatigue
- Electronic device access orders are enforceable when one parent controls accounts, with sanctions available for noncompliance
- Declining severance payments that reduce marital estate constitutes dissipation without proper justification
Practical Impact
For Petitioners
Document overscheduling concerns with expert testimony and seek specific electronic access provisions in parenting orders
For Respondents
Preserve detailed objections for bias claims and provide economic justification before declining financial benefits
When This Applies
Applies when one parent controls electronic accounts and children show fatigue from overscheduling, but may not apply with shared account control
Statutes Cited
Citation Network
This Case Cites
- In re Marriage of Lebovich
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