In re Marriage of Alpert Knight

Full Case Summary

Case Summary: In re Marriage of Amanda Alpert Knight

Court: Appellate Court of Illinois, First District, December 27, 2024
Case Number: 2024 IL App (1st) 230629

Background: Robert Knight and Amanda Alpert Knight divorced in 2015, incorporating a marital settlement agreement (MSA). Robert’s wealth largely came from extensive family trusts, valued at $37+ million. The MSA set child support at $10,000/month plus various expense splits, assuming an income range of $600k to $1.6M for Robert. Amanda eventually sought to modify child support after Robert’s income soared well beyond that range, arguing the children’s standard of living with Robert was far superior to her ability to provide.

Issue:

Whether Robert’s significant post-MSA income spike (into multi-million annual capital gains) constituted a “substantial change in circumstances” under Section 510, justifying a higher child support award. Amanda also wanted to present expert testimony on needed home repairs to show the children’s lesser standard of living in her household. She sought attorney fees, claiming financial disparity.

Key Points:

• The circuit court denied her motion, ruling the MSA anticipated Robert’s income changes. It also barred her experts on home repair costs as irrelevant.
• It denied her fee request, finding she had resources (including a $1M investment account) to handle her own legal costs.

Appellate Findings:

1. Child Support Modification: The appellate court reversed, emphasizing that multi-million gains exceeding the MSA’s upper bound were not necessarily “anticipated.” The law allows support above the child’s mere “basic needs” if a parent can afford it, to reflect a lifestyle they’d have if the marriage continued (see Bussey).
2. Expert Testimony: Excluding Amanda’s experts on repairs was an abuse of discretion if it helped show the children’s living standards. The court directed reconsideration of that testimony on remand.
3. Attorney Fees: The appellate court also reversed the blanket denial, instructing the lower court to weigh statutory factors more closely, including the parties’ relative finances and the reasonableness of her fees.

Conclusion: Partly affirmed—no error in limiting trust discovery, since Robert admitted he could pay a higher amount if ordered. But reversed the child support denial, reversed the fee denial, and remanded for further proceedings consistent with the children’s best interests and statutory guidelines.