In re Parentage of T.T., 2022 IL App (2d) 210547-U

- Case citation and parties
In re Parentage of T.T., 2022 IL App (2d) 210547-U (Ill. App. Ct., 2d Dist. Feb. 28, 2022). Petitioner-Appellee: Francesco P. Anguilo. Respondent-Appellant: Natasha T.

- Key legal issues
1) Allocation of parental responsibilities (decision‑making authority) under 750 ILCS 5/602.5 and parenting time under 750 ILCS 5/602.7 — what arrangement serves the child’s best interests; and
2) Whether the trial court properly restricted the mother’s parenting time and required supervised visits under 750 ILCS 5/603.10 based on safety/behavioral concerns. Jurisdictional tangles under the UCCJEA and interplay with an enrolled Florida order of protection were also implicated.

- Holding / outcome
The appellate court affirmed. The trial court’s award of significant decision‑making authority and majority parenting time to the father was upheld, as was the restriction requiring the mother’s visits to be supervised.

- Significant legal reasoning (concise)
The court reviewed the factual findings for manifest weight and deferred to the trial court’s credibility assessments. Key evidentiary bases supporting the trial court’s allocation included: the mother’s repeated noncompliance with Illinois court orders (including concealing the child and attempting to invoke a Florida protective order contrary to Illinois custody determinations, which prompted law‑enforcement involvement), evidence and allegations concerning the mother’s lifestyle (pornography/prostitution allegations and unstable relocations), and the child representative’s investigative report favoring the father’s capacity to provide a stable home. The father’s prior positive drug test did not outweigh the weight of other evidence because he submitted to testing, entered treatment, and subsequently tested negative. The court emphasized the child’s safety and stability as controlling, and that section 603.10 permits supervised parenting time where parental conduct poses risk to the child. The appellate court found no abuse of discretion or manifest‑weight error in the trial court’s balancing of best‑interest factors.

- Practice implications for family law attorneys
- Document and introduce concrete evidence (texts, police reports, treatment records, child‑rep reports) when alleging concealment, noncompliance, substance use, or sexualized/professional conduct that may endanger a child.
- Use contempt and emergency relief promptly where a parent conceals a child or violates custody orders; coordinated action across jurisdictions under the UCCJEA is critical.
- When a client has substance issues, documented remediation (testing, treatment, negative follow‑ups) can mitigate adverse findings.
- Seek supervised parenting time under §603.10 when safety concerns exist and be prepared to show specific risks to the child.
- Expect appellate deference to trial court credibility findings and factual allocations under the manifest‑weight standard; preserve a detailed record.