In re Marriage of Tiffany A.
Court: Illinois Appellate Court | Published: 10/21/2025
Marriage
Quick Summary:
<h3>Case</h3>
<strong>Citation:</strong> 2025 IL App (5th) 250409-U (No. 5-25-0409) — Illinois Appellate Court, Fifth District (appeal from Circuit Court of Madison County, No. 22‑DC‑257, Judge Mauree...
Full Case Summary
Case
Citation: 2025 IL App (5th) 250409-U (No. 5-25-0409) — Illinois Appellate Court, Fifth District (appeal from Circuit Court of Madison County, No. 22‑DC‑257, Judge Maureen D. Schuette).Parties
Petitioner–Appellant: Tiffany A.Respondent–Appellee: David A.
Procedural Posture
Two‑day dissolution hearing on allocation of parenting time for the parties’ two minor children; Tiffany appealed the trial court’s parenting‑time award (seeking majority time and challenging the guardian ad litem’s investigation/report as inadequate).Background & Key Facts
- Married 2014; children born 2015 and 2017. Family lived in Louisiana until May–June 2022 when Tiffany moved the children to Edwardsville, Illinois, and enrolled them in local schools without David’s consent. - Events included an order of protection, a DCFS investigation (allegation regarding David’s nephew later found unfounded), counseling for the children (at times scheduled during David’s parenting time), attendance problems (27 absences for L.R.A., including unexcused days), and discord/parenting‑time interference by Tiffany (including a roughly one‑month denial of contact). - David has a military service history, a PTSD diagnosis (medicated and in treatment), a DWI with remaining probation, and testified to reduced alcohol use since the move to Illinois. Tiffany acknowledged past excessive drinking and spends nights at her boyfriend’s residence; third parties testified variably about each parent’s fitness.Guardian ad Litem (GAL) Investigation
- Kelly Stephen (GAL) interviewed both parents, the children, and several witnesses, reviewed documents (texts, school records, discovery materials) and the children’s interviews from the DCFS process, and issued a report applying the statutory best‑interest factors (750 ILCS 5/602.5, 602.7). - GAL recommended David receive majority school‑year parenting time (and joint decision‑making); alternates were proposed if Tiffany relocated. Tiffany argued on appeal the GAL failed to perform duties under Ill. S. Ct. R. 907 (no school visits/teacher interviews, limited home visits, late witness disclosures). The trial court found the GAL’s investigation adequate and the appellate court agreed.Trial Court Findings & Parenting Plan
- After observing credibility and demeanor, the circuit court found significant parental conflict, instances of unilateral conduct by Tiffany (secret relocation, school enrollment, undisclosed counseling), and conduct interfering with David’s access. The court found no ongoing safety reason to preclude substantial time with David and noted the DCFS inquiry was unfounded. - Orders: joint decision‑making (education, health, religion, extracurriculars); parenting time awarding David majority time during the school year with Tiffany having 1st, 2nd, and 4th weekends each month, split holidays and breaks, week‑to‑week summer schedule (or weekly alternating if Tiffany relocates to Mendon); restrictions included no alcohol while supervising, no unsupervised contact with David’s nephew, helmet/safety rules, and nondisparagement. Mediation and GAL fees split 50/50. Child support later set at $359.08 every other week.Issues on Appeal & Appellate Ruling
- Tiffany argued the GAL’s report was deficient under Rule 907 and that the parenting‑time award was against the manifest weight of the evidence. - The appellate court held the GAL complied with Rule 907 and conducted a reasonable investigation, and that the trial court’s best‑interest analysis and factual findings were not against the manifest weight of the evidence. The court emphasized deference to the trial court’s credibility determinations and that Tiffany forfeited review of the joint‑decision‑making award by not challenging it on appeal.Disposition & Miscellaneous
Disposition: Affirmed — the Madison County circuit court’s parenting‑time order upheld. Opinion: Presiding Justice McHaney; Justices Moore and Vaughan concurred. Decision filed 10/14/2025. Non‑precedential: Filed under Ill. S. Ct. R. 23; not precedent except as Rule 23(e)(1) allows.Ask AI About This Case
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