In re Marriage of Taylor C., 2025 IL App (4th) 250061-U
Child Relocation Denied Under Best Interest Analysis
Illinois appellate court affirmed denial of mother's petition to relocate children from Macomb, IL to Greenville, SC. Court applied 609.2(g) multi-factor best interest analysis, finding relocation would harm established father-child relationship. Practitioners must provide comprehensive evidence addressing each statutory factor.
Facts
Mother Taylor C. petitioned to relocate two children from Macomb, Illinois to Greenville, South Carolina over father Joel V.'s objection. The trial court denied the relocation petition after conducting a best interest analysis under Illinois statute 750 ILCS 5/609.2(g). Mother appealed the denial.
Issue
Whether the trial court properly denied mother's petition to relocate children based on the statutory best interest factors under 750 ILCS 5/609.2(g).
Holding
The Fourth District affirmed the trial court's denial of relocation. The court properly applied the multi-factor analysis and found that relocation would not serve the children's best interests given their strong relationship with father and established ties in Illinois. The factual findings were not against the manifest weight of evidence.
Key Reasoning
- Appellate courts apply manifest weight standard giving deference to trial court's factual findings and credibility determinations
- Trial court properly weighed children's strong relationship with father and paternal family against proposed benefits of relocation
- Evidence supported finding that proposed parenting schedule would materially reduce meaningful father-child contact
- Court appropriately considered stability concerns and credibility issues regarding relocating family's motives
Practical Impact
For Petitioners
Must present comprehensive evidence for each 609.2(g) factor including objective data, detailed parenting plans preserving frequent contact, and documented stability at proposed location
For Respondents
Focus on established parent-child relationships, children's current stability, and inadequacy of proposed substitute contact arrangements
When This Applies
Applies when relocation significantly impacts existing parent-child relationships; less relevant when non-relocating parent has minimal involvement
Statutes Cited
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