In re Parentage of P.D.

Summary

The Illinois Appellate Court, Second District, reviewed the denial of Joan Dufelmeier’s petition to relocate her minor child, P.D., from Illinois to New Jersey. The court held that the trial court’s determination under section 609.2 of the Illinois Marriage and Dissolution of Marriage Act was not against the manifest weight of the evidence and affirmed. The court also addressed the statutory best-interest factors governing parental relocation.

Holdings

1. The trial court properly considered the statutory relocation factors and its denial of the petition was not against the manifest weight of the evidence.
2. Under the new statutory relocation directives, the court's analysis properly emphasized the child's best interests rather than treating enhancement of the custodial parent's quality of life as an independently controlling factor.
3. The claim was forfeited because Dufelmeier did not request closing argument or object, and in any event the trial court did not abuse its discretion by proceeding without oral argument in the bench trial.

Questions Presented

1. Whether the trial court's denial of Dufelmeier's petition to relocate P.D. to New Jersey was against the manifest weight of the evidence under section 609.2(g) of the Illinois Marriage and Dissolution of Marriage Act.
2. Whether the trial court committed reversible error by ruling on the relocation petition without hearing closing arguments.

Disposition

affirmed