In re Marriage of Stock, 2020 IL App (5th) 200175‑U

1) Case citation and parties
- In re Marriage of Stock, No. 5‑20‑0175 (Ill. App. Ct., 5th Dist., Nov. 16, 2020) (Rule 23 order; non‑precedential).
- Petitioner‑Appellee: Bethany S. Stock. Respondent‑Appellant: Robert W. Stock. Minor child: A.S.

2) Key legal issues
- Whether the trial court’s allocation of parental responsibilities under the Illinois Marriage and Dissolution of Marriage Act was against the manifest weight of the evidence.
- Whether the trial court properly considered evidence of substance abuse, psychological evaluations, GAL and therapist reports, contemptuous conduct, alleged abuse allegations, and the child’s stability in determining the child’s best interests.

3) Holding/outcome
- The appellate court affirmed the June 10, 2020 judgment allocating parental responsibilities (the trial court’s allocation in favor of the petitioner and limiting the respondent’s in‑person parenting time where appropriate). The allocation was not against the manifest weight of the evidence.

4) Significant legal reasoning
- Standard of review: allocation of parental responsibilities is reviewed for manifest weight of the evidence; appellate courts defer to the trial court’s factual findings and credibility assessments.
- The trial court properly relied on the statutory best‑interest framework and a full factual record: repeated positive drug tests, treatment records and conditional parenting tied to treatment, psychological evaluations, GAL appointment and interim reports, therapist testimony about the child’s need for stability and cautious reintroduction to the father, multiple violations of court orders (including failure to return the child and indirect civil contempt findings), social‑media postings by father accusing parties of conspiracies, and an unfounded DCFS determination regarding alleged abuse.
- The court emphasized child stability and safety; supervised/limited visitation and phased reintroduction were supported by the evidence. The appellate court found no abuse of discretion in the trial court’s weighing of those factors.

5) Practice implications (concise)
- Trial courts get wide deference on credibility and best‑interest determinations; appellate reversal requires manifestly contrary factual findings.
- Collect and present contemporaneous objective evidence: drug tests, treatment program records, psychological evaluations, GAL and therapist reports, DCFS findings, and documentation of order violations.
- Use supervised/stepwise visitation plans when substance abuse/parental noncompliance and stability concerns exist.
- Ensure clarity in temporary orders (exchange logistics, dates) to avoid disputes; promptly move for enforcement/contempt when orders are violated.
- Note: decision is Rule 23/non‑precedential—persuasive but not binding.