In re Marriage of O’Hare, 2017 IL App (4th) 170091, May 9, 2017, Sangamon Co., STEIGMANN,  Affirmed. Court entered dissolution of marriage order wherein court granted father parenting time with parties’ minor child (then age 4) every other Tuesday evening and every other Wednesday evening through Friday morning. Six years later, father filed motion to modify parenting time to every Wednesday and Thursday instead of every other Tuesday. Court properly granted mother’s motion to dismiss, finding that father’s request was not a “minor modification”. Father failed to allege specific facts supporting his motion, and court properly declined to accept his conclusory allegations as true. Father’s request was not “minor modification” as it would change parenting plan from one parent serving as primary custodial parent to both parents having equal parenting time. (HOLDER WHITE and APPLETON, concurring.)

In re Guardianship of Sanders, 2017 IL App (4th) 160502, May 9, 2017, Livingston Co., STEIGMANN, Vacated and remanded with directions. Section 513.5 of Marriage and Dissolution of Marriage Act authorizes awards of support from a former spouse to support the former spouse’s adult disabled children. In court proceedings under Probate Act, court may look to that support provision in Dissolution Act. Court should consider factors provided by Section 513.5(b) of Dissolution Act in deciding whether and how much support is appropriate. (HOLDER WHITE and KNECHT, concurring.)

In re Marriage of Haleas, 2016 IL App (2d) 160799, April 13, 2017, DuPage Co., JORGENSEN, Affirmed. Parties agreed to resolve their property and maintenance issues, in dissolution proceeding, through binding arbitration. Court properly confirmed arbitration award. As Respondent does not assert that award should be vacated or modified under Section 12 or 13 of Arbitration Act, or assert that a gross mistake of law or fact, evident on face of award, exists, Respondent’s arguments are beyond purview of judicial review of award. (SCHOSTOK and SPENCE, concurring.)

In re Parentage of J.W., 2017 IL App (2d) 160554, April 28, 2017, DuPage Co., McLAREN, Reversed and remanded. Attorney filed 3 motions for “interim attorney fees” on behalf of his client, seeking funds from Respondent father in parentage action. In a parentage action, court may order reasonable fees of counsel and costs to be paid by the parties in accordance with factors specified in Section 508 of Marriage and Dissolution of Marriage Act. Petitioner failed to request a hearing  on her 1st and 2nd petitions for attorney fees and thus forfeited her right to hearing for those petitions.  Where counsel has received no payment from his client due to hardship, court could order a contribution award to the party’s counsel. Attorney fees, while awarded to the client, actually belong to the attorney. A party has no right to contribution where she has paid nothing to her counsel. (ZENOFF and BURKE, concurring.)

In re Marriage of Faletti, 2017 IL App (3d) 160323, April 27, 2017, Kankakee Co., HOLDRIDGE, Reversed and remanded with directions. Son, as Guardian of Person and Estate of his father, filed petition for dissolution of marriage. Court erred in denying Respondents’ motion to vacate bifurcated judgment of dissolution. No indication that Respondents (Guardians of Person and Estate of wife) consented to entry of bifurcated judgment, and co-counsel for Respondents expressly reserved Respondents’ decision on whether to consent to judgment for wife’s guardian, who was later appointed. Co-counsel’s statement that Respondents “would agree” was not binding in later-appointed guardian. (LYTTON and SCHMIDT, concurring.)