In re Marriage of Mayfield

Summary

The Illinois Supreme Court held that a lump-sum workers’ compensation settlement constitutes income for purposes of calculating child support. Applying the statutory guideline of 20% of net income, the court upheld an award requiring the former husband to pay 20% of the entire settlement because he neither specifically requested a deviation from the guidelines nor presented sufficient evidence to support one. The court overruled In re Marriage of Wolfe to the extent it required justification for adhering to the guidelines in allocating a lump-sum settlement.

Holdings

1. A lump-sum workers' compensation settlement is income from all sources under section 505(a)(3) of the Illinois Marriage and Dissolution of Marriage Act and must be included in determining the noncustodial parent's net income.
2. When the obligor receives a lump-sum workers' compensation settlement and does not establish grounds for deviation, the statutory 20% guideline for one child may be applied to the entire net settlement rather than only to its prorated monthly equivalent.
3. Mayfield was not entitled to a downward deviation because he neither specifically requested a deviation from the statutory guidelines nor presented sufficient evidence supporting one.
4. In re Marriage of Wolfe was wrongly decided and is overruled because it effectively required a trial court to justify applying the statutory guidelines rather than requiring justification for departing from them.

Questions Presented

1. Whether a lump-sum workers' compensation settlement constitutes income under section 505(a)(3) of the Illinois Marriage and Dissolution of Marriage Act for purposes of calculating child support.
2. Whether the circuit court had discretion to apportion the settlement by applying the 20% child-support guideline only to the settlement's prorated monthly equivalent rather than to the entire lump sum.
3. Whether Mayfield presented sufficient evidence to justify a deviation from the statutory child-support guidelines.

Disposition

affirmed