In re Marriage of Zilligen
Court: Illinois Appellate Court | Published: 4/1/2025
Marriage
Quick Summary:
<h3>Case Overview</h3>
<strong>Case Citation:</strong> 2025 IL App (3d) 230529-U<br>
<strong>Filing Date:</strong> April 1, 2025<br>
<strong>Court:</strong> Appellate Court of Illinois, Third District...
Full Case Summary
Case Overview
Case Citation: 2025 IL App (3d) 230529-UFiling Date: April 1, 2025
Court: Appellate Court of Illinois, Third District
Judge: Honorable Richard D. Felice
Parties Involved
Petitioner/Appellant: Marjorie ZilligenRespondent/Appellee: Jon Zilligen
Background
Marjorie and Jon Zilligen were married in October 1996 and have four emancipated children. Marjorie primarily managed the household while Jon focused on his career. In April 2018, Marjorie filed for dissolution, which was finalized in August 2019. Jon was ordered to pay Marjorie $5,500 per month in indefinite modifiable maintenance due to her lack of employability and medical issues. Following Jon's reduced income due to the COVID-19 pandemic, he filed for a modification of his maintenance obligations.Modification Proceedings
Jon's maintenance payment was modified to $2,750 per month during a July 2021 hearing after an oral settlement was reached. Marjorie was required to reimburse Jon for previous overpayments and pay him $126,000 for his interest in the marital home. Jon's income fluctuated significantly following job changes, including a brief period of unemployment and subsequent part-time tutoring employment.Financial Overview
As of March 2022, Marjorie's financial affidavit revealed significant monthly expenses that exceeded her income from maintenance, leading to depletion of savings. Meanwhile, Jon's financial situation also evolved, as he secured a higher-paying position and reported income exceeding pre-modification levels.Contentions on Appeal
Marjorie appealed, asserting that the trial court misapplied the law by finding no substantial change in circumstances and failed to adequately consider the statutory guidelines during maintenance evaluations. She argued that Jon's increased income constituted a substantial change warranting a modification from the trial court.Trial Court's Findings
The trial court ultimately found there was no substantial change justifying a further modification of maintenance. While acknowledging changes since the last modification order, the court ruled that the increase in Jon's income did not necessitate an increase in maintenance as Marjorie's financial position was considered adequate. The court's decision emphasized the importance of statutory maintenance factors and that the prior judge's findings should be respected.Conclusion
The Appellate Court upheld the trial court's decision, affirming that it did not abuse its discretion in denying Marjorie’s petition for modification of maintenance.Ask AI About This Case
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