In re Marriage of Spangler, 2025 IL App (2d) 240303
Clear JPA Support Provisions Are Unambiguous
Joint parenting agreements with clear child support calculation provisions are unambiguous and enforceable. Courts apply contract interpretation principles focusing on plain language meaning. Parties cannot modify child support obligations through private oral agreements without court approval. Proper documentation prevents costly arrears and contempt proceedings.
Facts
Britt Spangler and Nathan DeFauw divorced with a joint parenting agreement requiring Nathan to provide annual income documentation and pay additional child support based on income increases. Nathan failed to comply, leading to $78,885.64 in arrears from 2015-2023. The trial court found Nathan in civil contempt and awarded attorney fees.
Issue
Whether the joint parenting agreement was ambiguous regarding Nathan's obligation to provide income documentation and pay increased child support, and whether oral modifications or equitable estoppel barred enforcement.
Holding
The appellate court affirmed, finding the JPA unambiguous and rejecting claims of oral modification. Under Blisset, parties cannot modify child support obligations without court approval since courts must protect children's interests. Civil contempt was appropriate for willful nonpayment.
Key Reasoning
- Contract interpretation under Quake Construction relies on plain language when text is not reasonably susceptible to multiple meanings
- Trial court properly rejected Nathan's self-serving explanations as insufficient to establish equitable estoppel or binding oral modification
- Blisset precedent prohibits out-of-court child support modifications because courts must protect children's interests
- Civil contempt sanctions including purge amounts and payment plans are appropriate to coerce compliance with support obligations
Practical Impact
For Petitioners
Draft JPA provisions with clear operative language about income disclosures and calculation mechanisms, and use contempt petitions proactively for non-compliance
For Respondents
Seek formal court approval for any support modifications rather than relying on informal agreements or course of conduct
When This Applies
Applies when JPA language is clear and unambiguous; different analysis may apply if contract terms are genuinely susceptible to multiple interpretations
Citation Network
This Case Cites
- Quake Construction
- In re Marriage of Blisset
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