In re Parentage of A.H., 2023 IL App (1st) 190572

1. Case citation and parties
- In re Parentage of A.H., 2023 IL App (1st) 190572.
- Petitioner/Appellee: Wipaporn T., individually and as parent and next friend of triplet minors A.H., A.H., and A.H.
- Respondent/Appellant: Harlow H.

2. Key legal issues
- Whether an Illinois court has statutory authority to modify a foreign (Thai) child‑support judgment (Uniform Interstate Family Support Act / “Support Act,” 750 ILCS 22).
- Proper application of Illinois child‑support law (including which statutory regime applies).
- Admissibility/relevance of evidence about immigration status (and exclusion of respondent’s immigration expert).
- Whether the trial court abused its discretion by: (a) modifying the foreign judgment (including retroactive modification and imposition of interest); (b) ordering creation/funding of multiple trusts for child support and attorneys’ fees; (c) appointing a receiver and entering injunctive relief; (d) awarding attorney fees and costs; and (e) imposing Rule 137 sanctions.

3. Holding / outcome (short)
- The appellate court affirmed in part, reversed in part, vacated in part, and remanded with directions. In particular, the court affirmed enforcement of past‑due support under the Thai judgment and several interim/procedural orders, but rejected or vacated other relief generated by the Illinois proceedings (including aspects of the modification, trust funding, and certain monetary awards), and remanded for further proceedings consistent with its opinion.

4. Significant legal reasoning (concise)
- Comity and UIFSA/Support Act principles control enforcement and modification of foreign child‑support judgments; an enrolled foreign judgment is enforceable, but modification authority is confined by statutory jurisdictional limits.
- The court emphasized the limits on an Illinois court’s power to modify a foreign order and on awarding retroactive increases beyond statutory authority; relief that functioned as de facto creation of new, large ongoing obligations (e.g., multi‑million dollar trusts and retroactive awards) required a proper statutory basis and careful factfinding.
- Procedural protections and relevance rules govern evidence: the trial court properly excluded immigration status evidence when it was not relevant to the child‑support/best‑interest analysis.
- Appointment of a receiver and entry of injunctive relief can be appropriate in limited circumstances to preserve assets for enforcement, but equitable orders must be tailored and supported by authority; the appellate court scrutinized the breadth and form of the trial court’s remedies.

5. Practice implications for family law attorneys
- When seeking enforcement or modification of a foreign support order in Illinois, counsel must identify and satisfy UIFSA/Support Act jurisdictional and procedural prerequisites — courts will enforce foreign arrearages but are cautious about substantive modification and large equitable remedies without clear statutory authorization.
- Emergency relief (receivers, injunctions) is available but must be narrowly tailored; expect appellate review of funding orders and trusts that effectively create ongoing obligations.
- Preserve admissibility issues and relevance of evidence: immigration status may be collateral and excluded unless directly relevant.
- Seek clear accounting of prior payments and credits; appellate courts require careful factual findings when altering obligations or awarding substantial fees or sanctions.
- Exercise caution before pursuing Rule 137 sanctions or seeking to fund attorneys’ fees by extraordinary equitable mechanisms; such remedies face close scrutiny and possible reversal.