In re Marriage of Mayfield, 2013 IL 114655

1. Case citation and parties
- In re Marriage of Mayfield, 2013 IL 114655 (Ill. May 23, 2013).
- Appellee: Shannon Mayfield (nee Dykes). Appellant: Howard R. Mayfield. Illinois Dept. of Healthcare & Family Services filed amicus brief.

2. Key legal issues
- Whether a lump-sum workers’ compensation settlement constitutes “income”/“net income” for child support under the Illinois Marriage and Dissolution of Marriage Act (750 ILCS 5/505).
- Whether child support should be calculated on the total lump sum or on the prorated monthly equivalent based on life expectancy, and whether a trial court must prorate when the obligor elected a lump sum under the Workers’ Compensation Act (820 ILCS 305/10.1).
- Whether deviation from the statutory guideline (20% for one child) is appropriate and, if so, whether the record here supported such a deviation.

3. Holding/outcome
- Supreme Court affirmed the appellate court and trial court: the lump-sum workers’ compensation award is income and the trial court properly ordered payment of 20% of the lump sum as child support. Affirmed judgment requiring payment of $47,984 (20% of the net settlement).

4. Significant legal reasoning
- The Court applied the two-step child support framework: (1) determine net income (broadly defined as “total of all income from all sources,” 750 ILCS 5/505(a)(3)) and (2) apportion using statutory guidelines (20% for one child under 505(a)(1)), with permitted deviation only upon explicit findings (505(a)(2)).
- Workers’ compensation payments replace lost wages and therefore fall within the statutory definition of income (following In re Marriage of Dodds and Schacht).
- A lump sum elected under the Workers’ Compensation Act represents capitalized present value of future payments; absent timely and adequate proof warranting a deviation, the court may treat the realized lump sum as current income (analogous to a lump-sum employment or investment receipt).
- The obligor did not request a deviation at trial nor present sufficient evidence (e.g., showing financial need or that applying 20% to the lump sum would be unjust); therefore, the court had no basis to deviate. Trial courts retain authority to deviate but must state reasons and compute guideline amount.

5. Practice implications
- For payors: electing a lump-sum workers’ comp settlement risks immediate inclusion of the lump sum as income for child support; structure settlements with counsel to anticipate support exposure (consider negotiated periodic payments or stipulations addressing support).
- For obligees: treat a lump-sum receipt as actionable income and move promptly for modification/arrest of funds.
- For counsel seeking deviation: timely request deviation with concrete evidence (child’s needs, custodial parent’s resources, obligee’s limited capacity, expert valuation tying award to future payments, or other equitable factors) and obtain explicit written findings per 505(a)(2).
- Litigation tip: preserve and introduce records showing allocation intent in the comp agreement, cash disbursement/use of proceeds, and any steps taken to notify the other parent—absence of such evidence undermines deviation arguments.