In re Marriage of Taylor, 2019 IL App (3d) 190062-U

1. Case citation and parties
- In re Marriage of Taylor, 2019 IL App (3d) 190062‑U (Ill. App. Ct., 3d Dist. May 22, 2019) (Rule 23 order).
- Petitioner‑Appellant: Cassandra Taylor; Respondent‑Appellee: Daniel Taylor.

2. Key legal issues
- Whether the trial court abused its discretion or rendered a decision against the manifest weight of the evidence by (a) declining to adopt the husband’s requested 50/50 week‑on/week‑off parenting time and instead awarding a mostly traditional schedule (the husband receiving ≈43% parenting time), and (b) awarding joint decision‑making authority for the children’s religious upbringing.

3. Holding / outcome
- The appellate court affirmed. The parenting‑time allocation and the joint decision‑making order as to religion were not against the manifest weight of the evidence and did not constitute an abuse of discretion.

4. Significant legal reasoning
- Standard of review: allocation of parenting time and decision‑making are committed to the trial court’s broad discretion; appellate reversal requires abuse of discretion or a decision against the manifest weight of the evidence. Credibility assessments rest with the trial court.
- The trial court expressly applied the best‑interests framework in 750 ILCS 5/602.7(b) and considered relevant factors (parental involvement, historic caretaking roles, routines, communication issues, logistics). Evidence showed the wife had been the primary daytime caretaker (teacher schedule, pickup routines, medical care), while the husband had meaningful, but lesser, caretaking involvement and had a history of daily alcohol use (but testified he stopped). The parents attended the same church and no religious conflict was shown.
- The court concluded a 50/50 rotating schedule would not serve the children’s best interests and adopted a schedule maximizing meaningful time with both parents while preserving continuity and practical exchange points (school). Joint decision‑making on religion was appropriate because both parents practiced the same faith and no conflict over religion was evident.

5. Practice implications for family attorneys
- Trial courts get wide deference on parenting allocations; appellate courts will uphold orders grounded in explicit best‑interest factor analysis and credibility findings.
- To seek 50/50 time, present strong evidence demonstrating equal historic caretaking, stable logistics for exchanges, and lack of factors (e.g., substance misuse, poor communication) that would disrupt children’s routines.
- To oppose equal time, emphasize continuity, primary caregiver role, children’s routines, and exchange feasibility.
- When arguing decision‑making on religion, demonstrate either a shared, noncontroversial religious practice (supporting joint authority) or show real conflict/concern to justify sole decision‑making.
- Always elicit and preserve findings on specific 602.7 factors to aid appellate review.