In re Marriage of Turner, 2025 IL App (3d) 250246-U

Facts

Alexander and Lyndsey Turner divorced with disputes over parenting time and decision-making authority for their children. The trial court awarded Lyndsey sole decision-making responsibility and majority parenting time based on evaluator findings about Alexander's narcissistic traits and controlling behavior. Alexander appealed both the initial allocation and denial of his modification petition.

Issue

Whether the trial court erred in its parenting allocation decisions and in admitting expert testimony regarding narcissistic personality traits without formal clinical diagnosis.

Holding

The appellate court affirmed, finding the trial court's best-interest determinations were supported by evidence of problematic parenting behaviors. The court emphasized that observable narcissistic traits and their impact on children mattered more than whether a formal NPD diagnosis was clinically precise.

Key Reasoning

• Courts apply manifest weight standard to allocation findings and abuse of discretion standard to evidentiary rulings
• Multiple experts and GAL agreed on Alexander's narcissistic traits and controlling behavior affecting parenting
• Section 604.10 evaluations with psychological assessments are admissible when tied to statutory best-interest factors
• Rule 213(f) disclosure violations don't automatically bar expert testimony absent showing of specific prejudice