In Re Marriage of Eckert, 518 N.E.2d 1041 (Ill. 1988). · Go Syfert
In Re Marriage of Eckert, 518 N.E.2d 1041 (Ill. 1988). Cases Citing This Book View Copy Cite
Quick Summary

A determination of the best interests of the child must be made on a case-by-case basis depending upon the specific circumstances of each case.

A custodial parent petitioned to remove a minor child from Illinois to Arizona for career advancement and to improve the health of a child from a previous marriage. The trial court denied the petition, finding the move was not in the child's best interests due to the father's strong relationship with the child and the child's ties to extended family. The appellate court reversed, applying a standard that required only a prima facie showing of sensible reasons for the move. The Supreme Court reversed the appellate court, holding that the statutory burden of proof rests on the moving parent to establish that the relocation is in the child's best interests based on a case-by-case evaluation of all relevant circumstances.

1,632 citation events (1,034 in the last 25 years) across 9 distinct courts.
Strongest positive: In re Marriage of Macias (illappct, 2020-05-14)
Treatment trajectory · 1988 → 2026 · click a year to view as-of
1988 2007 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) In re Marriage of Macias (2×) also: Cited as authority (rule)
Ill. App. Ct. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
a reasonable visitation schedule is one that will preserve and foster the child's relationship with the noncustodial parent.
discussed Cited as authority (rule) In re Marriage of Belt
Ill. App. Ct. · 2026 · confidence medium
Determination of a child’s best interests “cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending to a great extent upon the circumstances of each case.” Kavchak, 2018 IL App (2d) 170853, ¶ 65 (citing In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988)). 38 ¶ 136 On appeal, we do not “reweigh the competing considerations.” Kavchak, 2018 IL App (2d) 170853, ¶ 65 .
discussed Cited as authority (rule) In re S.Y.
Ill. App. Ct. · 2025 · confidence medium
See Kenney, 2023 IL App (1st) 221558, ¶ 36 (citing Kimberly R., 2021 IL App (1st) 201405 , ¶ 78; Levites, 2021 IL App (2d) 200552, ¶ 61 ); see also In re Parentage of P.D., 2017 IL App (2d) 170355, ¶ 15 ; and In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988)). ¶ 25 Ryan is also correct that the applicable standard of review is manifest weight of the evidence.
discussed Cited as authority (rule) Walker v. Tillman
Ill. App. Ct. · 2025 · confidence medium
A best interests determination “‘cannot be reduced to a simple bright-line test’” and a ruling on the best interests of a child “‘must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.’” Id. (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988)).
discussed Cited as authority (rule) Jamie G. v. Jonathan W.
Ill. App. Ct. · 2025 · confidence medium
Our role is to determine whether the decision the trial court reached—which we approach deferentially due to the trial court’s superior position to “ ‘observe both parents’ ” and “ ‘assess and evaluate their temperaments, personalities, and capabilities’ ” (In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988) (quoting Gallagher v. Gallagher, 60 Ill.
discussed Cited as authority (rule) In re Marriage of Smith
Ill. App. Ct. · 2025 · confidence medium
The court also stressed that “ ‘[a] trial court’s determination of what is in the best interests of the child should not be reversed unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.’ ” Id. (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988)).
discussed Cited as authority (rule) In re Marriage of Taylor C. (2×) also: Cited "see"
Ill. App. Ct. · 2025 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988).
discussed Cited as authority (rule) In re Marriage of Ebenezer
Ill. App. Ct. · 2025 · confidence medium
Id. “ ‘[A] trial court’s determination of what is in the best interests of the child should not be reversed unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.’ ” Id. (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988)).
discussed Cited as authority (rule) In re Marriage of Kayla T.
Ill. App. Ct. · 2025 · confidence medium
Though this statute outlines relevant considerations, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988). “ ‘In child custody cases, there is a strong and compelling presumption in favor of the result reached by the trial court because it is in a superior position to evaluate the evidence and determine the best interests of the child.’ ” Young v. Herman, 2018 IL A…
discussed Cited as authority (rule) In re Marriage of S.F.
Ill. App. Ct. · 2024 · confidence medium
At issue in this case was the best interests of the children and our supreme court has stated that “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
discussed Cited as authority (rule) In re Marriage of Eckburg
Ill. App. Ct. · 2024 · confidence medium
The court shall consider the following factors: (1) the circumstances and reasons for the intended relocation; (2) the reasons, if any, why a parent is objecting to the intended relocation; (3) the history and quality of each parent’s relationship with the child and specifically whether a parent has substantially failed or refused to exercise the parental responsibilities allocated to him or her under the parenting plan or allocation judgment; (4) the educational opportunities for the child at the existing location and at the proposed new location; - 33 - 2024 IL App (2d) 240471-U (5) the pr…
discussed Cited as authority (rule) Taylor v. Bradford
Ill. App. Ct. · 2024 · confidence medium
Those factors include, inter alia, the following: “(1) the wishes of each parent seeking parenting time; (2) the wishes of the child, taking into account the child’s maturity and ability to express reasoned and independent preferences as to parenting time; (3) the amount of time each parent spent performing caretaking functions with respect to the child in the 24 months preceding the filing of any petition for allocation of parental responsibilities or, if the child is under 2 years of age, since the child’s birth; - 15 - (4) any prior agreement or course of conduct between the parents r…
discussed Cited as authority (rule) In re Marriage of Erikson
Ill. App. Ct. · 2024 · confidence medium
Specifically, she contends the court failed to consider the greater weight of the evidence regarding (1) the quality of each parent’s relationship with the children and (2) whether the court could minimize impairment to the parent-child relationship and fashion a reasonable accommodation of parenting time. ¶ 27 “A determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
discussed Cited as authority (rule) In re Marriage of Norris
Ill. App. Ct. · 2024 · confidence medium
In determining whether relocation is in a child’s best interests, the trial court must consider the following 11 factors: “(1) the circumstances and reasons for the intended relocation; (2) the reasons, if any, why a parent is objecting to the intended relocation; (3) the history and quality of each parent’s relationship with the child and specifically whether a parent has substantially failed or refused to exercise the parental responsibilities allocated to him or her under the parenting plan or allocation judgment; (4) the educational opportunities for the child at the existing locatio…
discussed Cited as authority (rule) In re Marriage of Mehta
Ill. App. Ct. · 2024 · confidence medium
When deciding whether relocation is appropriate, the circuit court should hear “any and all relevant evidence.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988). ¶ 23 A reviewing court does not reweigh the competing considerations.
cited Cited as authority (rule) In re Marriage of Pauley
Ill. App. Ct. · 2024 · confidence medium
In deciding whether relocation is in the child’s best interests, a trial court should hear “any and all relevant evidence.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
discussed Cited as authority (rule) Adams v. Ogunoshun
Ill. App. Ct. · 2024 · confidence medium
Most critically, “ ‘ “ ‘[t]he presumption in favor of the result reached by the trial court is always strong and compelling in this type of case.’ ” ’ ” Kenney, 2023 IL App (1st) 221558, ¶ 33 (quoting Fatkin, 2019 IL 123602 , ¶ 32, quoting In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988), quoting Gallagher v. Gallagher, 60 Ill.
discussed Cited as authority (rule) In re Marriage of Erikson
Ill. App. Ct. · 2023 · confidence medium
“A determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988). ¶ 10 The standards a court must use in determining a child’s best interests in a relocation request are set forth in section 609.2(g) of the Illinois Marriage and Dissolution of Marriage Act: 3 “(g) The court shall modify the parenting plan or allocation judgment in accordance with the child’s best interests.
discussed Cited as authority (rule) In re Marriage of Kenney (2×) also: Cited "see"
Ill. App. Ct. · 2023 · confidence medium
As such, and significantly, “ ‘ “[t]he presumption in favor of the result reached by the trial court is always strong and compelling in this type of case.” ’ ” Fatkin, 2019 IL 123602, ¶ 32 (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988), quoting Gallagher v. Gallagher, 60 Ill.
cited Cited as authority (rule) Shawnandriana D. v. Brandon O.
Ill. App. Ct. · 2023 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988).
discussed Cited as authority (rule) In re Marriage of Kenney
Ill. App. Ct. · 2023 · confidence medium
We will discuss this more below, but at this juncture, we certainly do not see how the trial court’s consideration of the twins’ best interests when deciding Amber’s relocation petition, which is authorized, and even demanded, by the relocation statute at issue, would be considered an abrogation or misapplication of the law requiring de novo review on appeal. ¶ 32 Our point here is this: we are not persuaded by John’s assertion that we are to apply de novo review to the instant matter, and we find no reason to depart from our well-established case law holding the exact opposite to be …
discussed Cited as authority (rule) In re Marriage of Mardi L.A.
Ill. App. Ct. · 2023 · confidence medium
The Illinois Supreme Court “has explained that a best interests determination ‘cannot be reduced to a simple bright-line test’ and that a ruling on the best interests of a child ‘must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.’ ” In re Marriage of Fatkin, 2019 IL 123602, ¶ 32 , 129 N.E.3d 1230 (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988)).
discussed Cited as authority (rule) In re Marriage of Lippert
Ill. App. Ct. · 2022 · confidence medium
Our supreme court has held “that ‘[a] trial court's determination of what is in the best interests of the child should not be reversed unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.’ ” Scott v. Haritos, 2022 IL App (1st) 220074, ¶ 45 (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988)); see also In re Marriage of Yabush, 2021 IL App (1st) 201136, ¶ 28 .
discussed Cited as authority (rule) Scott v. Haritos
Ill. App. Ct. · 2022 · confidence medium
In this context, our supreme court has explained that a best interests determination “cannot be reduced to a simple bright-line test” and that a ruling on the best interests of a child “must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
discussed Cited as authority (rule) In re The Marriage of Jarecki
Ill. App. Ct. · 2022 · confidence medium
Because a child has an interest in maintaining significant contacts with both parents following a divorce, “the mere desire of the custodial parent to move to another State, without more, is insufficient to show that the move would be in the [child’s] best interest.” In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988).
discussed Cited as authority (rule) Smith v. Small
Ill. App. Ct. · 2022 · confidence medium
We will not reverse a trial court’s best-interest determination “unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.” In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988).
cited Cited as authority (rule) Adam V. v. Victoria W.
Ill. App. Ct. · 2022 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988).
discussed Cited as authority (rule) Siegel v. Siegel
Ill. App. Ct. · 2021 · confidence medium
See In re Marriage of Levites, 2021 IL App (2d) 200552, ¶ 57 ; see also In re Marriage 19 of Collingbourne, 204 Ill. 2d 498, 521 (2003) (court emphasized that the consideration of the best interests of the child is the “ ‘paramount question’ ” in removal actions). ¶ 64 The statutory factors outlined in section 609.2(g) of the Marriage Act are as follows: “(1) the circumstances and reasons for the intended relocation; (2) the reasons, if any, why a parent is objecting to the intended relocation; (3) the history and quality of each parent’s relationship with the child and specifica…
cited Cited as authority (rule) In re Marriage of Barsky
Ill. App. Ct. · 2021 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988).
discussed Cited as authority (rule) In re Marriage of Whitney H.
Ill. App. Ct. · 2021 · confidence medium
Though the statutes outline relevant considerations, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 , 518 N.E.2d 1041, 1045 (1988). ¶ 29 “ ‘In child custody cases, there is a strong and compelling presumption in favor of the result reached by the trial court because it is in a superior position to evaluate the evidence and determine the best interests of the child.’ �…
discussed Cited as authority (rule) Department of Healthcare & Family Services ex rel. Rikayla P. v. Alan R.
Ill. App. Ct. · 2021 · confidence medium
Our supreme court has held, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
discussed Cited as authority (rule) Villareal v. Medina
Ill. App. Ct. · 2021 · confidence medium
“A trial court’s determination of what is in the best interests of the child should not be reversed unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.” In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988). ¶ 96 When a parent files a petition to relocate with a minor and the other parent objects, a court considers the factors listed in section 609.2(g) of the Act “in accordance with the child’s best interests.” 750 ILCS 5/609.2(g) (West 2018).
discussed Cited as authority (rule) Michael C. v. Amber B.
Ill. App. Ct. · 2021 · confidence medium
This court will not reverse a circuit court’s determination of what is in the child’s best interests “unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.” In re Marriage of Eckert, 119 Ill. 2d 316, 328 , 518 N.E.2d 1041, 1046 (1988); see also Jameson v. Williams, 2020 IL App (3d) 200048, ¶¶ 47, 53 , 165 N.E.3d 501 (noting both the circuit court’s ruling on the allocation of parenting time and decision-making responsibilities will not be disturbed unless they are against the manifest weight of the evidence).
cited Cited as authority (rule) In re Marriage of Allaman
Ill. App. Ct. · 2021 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988).
discussed Cited as authority (rule) Wise v. Williams
Ill. App. Ct. · 2021 · confidence medium
The trial court found M.W.’s relationship with her half-brother to be a significant factor, noting it should be fostered as much as any other relationship, including M.W.’s relationship with her parents. ¶ 65 Our supreme court has held a best interest determination “cannot be reduced to a simple bright-line test” and a ruling on the best interests of a child “must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Fatkin, 2019 IL 123602, ¶ 32 (quoting In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988)).
discussed Cited as authority (rule) In re Marriage of Schouten (2×) also: Cited "see"
Ill. App. Ct. · 2021 · confidence medium
He assessed the factors discussed by the supreme court in In re Marriage of Eckhart, 119 Ill. 2d 316, 326-28 (1988), as well as the 11 factors set forth in section 609.2(g) of the Act (750 ILCS 5/609.2(g) (West 2016)), finding as follows: 750 ILCS 5/609.2(g) GAL’s Findings Factors 1.
discussed Cited as authority (rule) In re Marriage of Stock
Ill. App. Ct. · 2020 · confidence medium
“A trial court’s determination of what is in the best interests of the child should not be reversed unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred.” In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988).
discussed Cited as authority (rule) In re Marriage of Prusak (2×) also: Cited "see"
Ill. App. Ct. · 2020 · confidence medium
“A determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988); In re Marriage of Kavchak, 2018 IL App (2d) 170853, ¶ 65 . ¶ 38 Our review of the record in this regard reveals no error in the circuit court’s application of the law to the facts of this case.
discussed Cited as authority (rule) In re Marriage of Kent
Ill. App. Ct. · 2020 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 328 (1988). ¶ 114 Colleen notes that, at trial, the court heard testimony concerning Luis’s February 5, 2019, petition for rule to show cause, which alleged Colleen’s failure to comply with the parenting plan and allocation judgment, as well as Colleen’s failure to participate in mediation.
cited Cited as authority (rule) In re Marriage of Adler
Ill. App. Ct. · 2020 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988); 750 ILCS 5/609.2(g) (West 2016).
cited Cited as authority (rule) Tessa M.S. v. Eric T.S.
Ill. App. Ct. · 2019 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 325 (1988).
discussed Cited as authority (rule) In re Marriage of Fatkin
Ill. · 2019 · confidence medium
In this context, this court has explained that a best interests determination “cannot be reduced to a simple bright-line test” and that a ruling on the best interests of a child “must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
cited Cited as authority (rule) Williams v. Williams
Ill. App. Ct. · 2018 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
discussed Cited as authority (rule) In re Marriage of Adams
Ill. App. Ct. · 2018 · confidence medium
When the children visit their father, they also can see other family members, including grandparents, aunts, uncles, and cousins of the father’s new wife. ¶ 12 In ruling on the petition to modify parenting time due to the mother’s relocation, the trial court noted that the mother never filed a motion for leave to relocate, but it reviewed the section 609.2 factors (750 ILCS 5/609.2 (West 2016)), which are the codified Eckert factors (In re Marriage of Eckert, 119 Ill. 2d 316, 325-27 (1988)), and concluded that it would not have granted a petition to relocate.
examined Cited as authority (rule) In re Parentage of P.D. (4×) also: Cited "see"
Ill. App. Ct. · 2017 · confidence medium
See id.; In re Parentage of Rogan M., 2014 IL App (1st) 141214, ¶ 8 . ¶ 16 In applying section 609, the Illinois Supreme Court stated, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
examined Cited as authority (rule) In re Parentage of P.D. (4×) also: Cited "see"
Ill. App. Ct. · 2017 · confidence medium
See id.; In re Rogan M., 2014 IL App (1st) 141214, ¶ 8 . ¶ 16 In applying section 609, the Illinois Supreme Court stated, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
examined Cited as authority (rule) In re Parentage of P.D. (4×) also: Cited "see"
Ill. App. Ct. · 2017 · confidence medium
See id.; In re Rogan M., 2014 IL App (1st) 141214, ¶ 8 . ¶ 16 In applying section 609, the Illinois Supreme Court stated, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re -5- 2017 IL App (2d) 170355 Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
examined Cited as authority (rule) In re Parentage of P.D. (4×) also: Cited "see"
Ill. App. Ct. · 2017 · confidence medium
See id.; In re Rogan M., 2014 IL App (1st) 141214, ¶ 8 . ¶ 16 In applying section 609, the Illinois Supreme Court stated, “[a] determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” In re -5- 2017 IL App (2d) 170355 Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
cited Cited as authority (rule) In re Marriage of Betsy M.
Ill. App. Ct. · 2016 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
cited Cited as authority (rule) In re Marriage of Betsy M.
Ill. App. Ct. · 2015 · confidence medium
In re Marriage of Eckert, 119 Ill. 2d 316, 326 (1988).
Retrieving the full opinion text from the archive…
In Re MARRIAGE OF CAROL LEE ECKERT, Appellee, and MARK WILLIAM ECKERT, Appellant
64589.
Illinois Supreme Court.
Jan 19, 1988.
518 N.E.2d 1041
1988 Ill. LEXIS 3
Steven E. Katzman, of Katzman & Associates, of Belleville, for appellant., Phillip A. Montalvo, of McRoberts, Sheppard, Wimmer & Stiehl, P.C., of Belleville, for appellee.
Ryan, Simon.
Cited by 188 opinions  |  Published
JUSTICE RYAN

delivered the opinion of the court:

The custodial parent, Carol Eckert, petitioned the trial court for leave to remove the parties’ son, Matthew, from the State of Illinois to Arizona. The trial court denied the petition for removal, because the court found the best interests of the child would be served by his continued residence in Illinois near his father and extended family, including all of his surviving grandparents. The petitioner appealed from that judgment, and the appellate court concluded that the trial court’s denial of the petition was against the manifest weight of the evidence and that the best interests of the minor would be served by allowing removal to Arizona. (148 Ill. App. 3d 512.) We granted respondent Mark Eckert’s petition for leave to appeal. 107 Ill. 2d R. 315.

Carol and Mark Eckert were married on June 30, 1976. The parties’ marriage was dissolved on December 18, 1983; custody of the parties’ minor son, Matthew (seven years old at the time of the instant petition), was awarded to Carol, subject to rather extensive visitation rights for Mark. The petitioner has another son from her first marriage, Bernie Plassmayer, who has asthma. On May 23, 1985, Carol filed a petition for leave to remove Matthew from Illinois to Yuma, Arizona. The petition for removal was based upon two grounds: (1) advancement of Carol's career both professionally and economically, and (2) improvement of Bernie’s (her son from a previous marriage) health. Mark objected to the removal and asserted that Carol’s interest in moving to Yuma was self-motivated and not in the best interests of the child, Matthew. Additionally, Mark asserted that the proposed move would cause grave psychological trauma for Matthew and would irrevocably injure the close parent-child relationship between father and son.

Mark Eckert filed a petition for the appointment of a court-ordered psychological evaluation of the parties and the minor child in order to ascertain whether the proposed move was in the best interests of Matthew. The petitioner, Carol Eckert, objected to the petition for psychological evaluation and alternatively argued that the trial court should order Mark Eckert to authorize the release of all information obtained by Dr. Tom Evans. Dr. Evans is a psychologist that extensively counseled the couple and allegedly had information which would aid the trial court in determining the best interests of Matthew. The trial court granted Mark Eckert’s petition for psychological evaluation of the parties and their minor son. The trial court appointed Dr. Daniel J. Cuneo, who frequently serves the St. Clair County circuit court as a court-appointed psychologist. Petitioner, Carol Eckert, on appeal asserted that the trial court erred in denying the release of any and all information Dr. Evans may have had regarding the best interests of Matthew. No offer of proof was made by Carol Eckert that would indicate what information Dr. Evans had regarding the bests interests of Matthew.

At the time of the hearing on the petition for removal, Carol was teaching nursing at East St. Louis State Community College. She had been offered a teaching position at the Junior College of Yuma, Arizona. The associate degree nursing program at the Junior College of Yuma is fully accredited, whereas the program at East St. Louis State Community College is unaccredited. Carol testified that the pay scale for the job in Yuma ranged from $19,000 to $23,000, and that her salary was $21,350 at East St. Louis State Community College. Carol further testified that she had been looking for a position in the Belleville area through the newspapers, without success. On cross-examination, however, Carol admitted that she “wasn’t really looking” for work and that she had just been offered the job in Yuma.

The second reason Carol gave for her desire to move to Arizona was Bernie’s (her son from a previous marriage) asthmatic condition. Carol Eckert’s father, Dr. William Knaus, testified that the climate of Belleville, Illinois, is unfavorable to asthmatics. Carol also presented evidence that the quality of life for the children would be at least equal to that offered in Belleville, because their housing, schooling and activities would be comparable, and possibly enhanced, by an improved climate. Carol had previously lived in Yuma and therefore is familiar with the living and environmental conditions there. Additionally, evidence was introduced that Carol was dating a physician in Yuma with some talk of marriage, but no definite plans.

All the evidence introduced indicated that Matthew is well adjusted and that both mother and father are excellent, loving parents. Although each party attempted to disparage, to a degree, the custody circumstances of the other, the record reflects that Matthew has developed a strong attachment for his father, as well as for his mother. The court-appointed psychologist, Dr. Cuneo, evaluated the parties and minor child and concluded that Matthew’s best interest would be served by remaining in the Belleville area. Dr. Cuneo stated:

“Mr. Eckert has an excellent relationship with his son, one of the best I’ve seen. He is involved in all aspects of his son’s life. As the result of Mr. Eckert’s love, concern, and time spent with his son, Matt has an excellent relationship with his father. This relationship has been very beneficial to Matt. It has been one of the contributing factors to Matt's well adjustment.”

Mark Eckert is employed as a funeral home attendant, ambulance driver, and emergency medical technician. Mark’s work schedule varies; nevertheless, he has never missed a visitation with his son. Several witnesses testified that Mark is an exceptional parent and that he spends a great deal of quality time with Matthew. Moreover, there was considerable testimony that Carol had attempted to interfere -with Mark’s visitation rights. Specifically, Karen Neimann testified that when she baby-sat for Matthew during the summer of 1982, the petitioner, Carol Eckert, told her Matthew was not allowed to call his paternal grandmother, who lived a few blocks away. Similarly, Matthew’s first-grade teacher, Annie Mae Banes, testified that she allowed parents to go on field trips. According to Banes, she gave Mark Eckert permission to go on the field trip, not knowing the family situation. When she found out, she told Carol Eckert she could go on the next field trip. Banes testified that Carol Eckert told her “she was going to keep him [Matthew] home and he was going to be sick.”

In the order denying the petition to remove, the trial court concluded that Carol had not sought employment in the St. Louis area, there was no evidence introduced on how the move to Yuma would improve Bernie’s asthma, respondent has an exceptional relationship with his son and spends a great deal of quality time with him, the father’s relationship with Matt is important at his age, the move would substantially reduce their time together, and finances would prohibit more than an occasional visit. The trial court concluded that: “A move to Yuma (disregarding the effect of a diminishment of visitation and contacts with the minor’s extended family) would be neutral ***. When this exceptional relationship [between Matt and his father], in a nurturing environment, is viewed against a neutral effect of a move to Yuma, the child’s best interests are favored by a continuation of the present situation.”

The appellate court, with one justice dissenting, reversed the trial court and held that denial of the petition for removal was against the manifest weight of the evidence. The appellate court stated that a petition for removal should be granted “unless rather strong negative circumstances militate against it.” (148 Ill. App. 3d 512, 515-16.) Additionally, the appellate court noted that “[dilution of rights of visitation have not constituted such negative factors that will prohibit removal.”

The appellate court relied on the standard set out in In re Marriage of Burgham (1980), 86 Ill. App. 3d 341, to determine if a court should grant a petition for removal:

“[T]he petitioning spouse has the burden of proof. However, a prima facie showing is made when a proper custodian states a desire to remove, shows a sensible reason for the move, and makes at least a superficial showing that the move is consistent with the child’s best interests. As a child often receives little, if any, demonstrable benefit from moving, direct benefit need not be shown. A different rule would unnecessarily tie many custodial spouses to this State. As proof that the child would not be harmed by the move involves proof of a negative, the petitioning spouse need not negate all possibilities of harm to the child. An objecting party could, of course, introduce evidence of specific damage likely to be incurred by the child. If the noncustodial spouse has rights of visitation, the trial court must give consideration to these rights and, with rare exceptions, should not allow removal if it would prevent reasonable visitation by the noncustodial spouse. The trial court must then weigh all of these items of evidence in arriving at its conclusion.” (Emphasis added.) (86 Ill. App. 3d at 345-46.)

The appellate court found that the trial court’s decision was against the manifest weight of the evidence because: (1) Carol had a plausible reason for the move; (2) Carol’s two sons had a strong attachment to each other and would remain together; (3) Carol had been dating a physician in Yuma with some talk of marriage; and (4) the only detriment Mark could establish was the diminution of visitation. 148 Ill. App. 3d 512.

Mark asserts that the appellate court’s decision renders the best interests of the child requirement of section 609 of the Illinois Marriage and Dissolution of Marriage Act (Ill. Rev. Stat. 1985, ch. 40, par. 609) meaningless because the removing parent can offer any reason for wanting to leave the State and the petition will be granted. We agree with the respondent and reverse the judgment of the appellate court and reinstate the order of the trial court.

Section 609 of the Illinois Marriage and Dissolution of Marriage Act (Ill. Rev. Stat. 1985, ch. 40, par. 609) provides:

“The court may grant leave, before or after judgment, to any party having custody of any minor child or children to remove such child or children from Illinois whenever such approval is in the best interests of such child or children. The burden of proving that such removal is in the best interests of such child or children is on the party seeking the removal. When such removal is permitted, the court may require the party removing such child or children from Illinois to give reasonable security guaranteeing the return of such children.” (Emphasis added.)

In removal cases the paramount question is whether the move is in the best interests of the child. (Quirin v. Quirin (1977), 50 Ill. App. 3d 785, 788.) Because of the children’s interest in maintaining significant contact with both parents following the divorce, it has been held that the mere desire of the custodial parent to move to another State, without more, is insufficient to show that the move would be in the children’s best interest. (See Reddig v. Reddig (1973), 12 Ill. App. 3d 1009, 1011; see also Ill. Rev. Stat. 1985, ch. 40, par. 102(7).) Moreover, it is clear from the italicized language of section 609 quoted above that the burden of proof is on the party seeking judicial approval of the proposed removal to establish that the move is in the children’s best interest. (Quirin, 50 Ill. App. 3d 785.) The italicized language was added to section 609 by amendment effective January 1, 1982, to clarify the question as to which party will bear the burden of proof in removal proceedings. Prior to the amendment, this question had not been uniformly decided by case law. See Ill. Ann. Stat., ch. 40, par. 609, Supplement to Historical & Practice Notes, at 50 (Smith-Hurd 1987 Supp.).

In determining whether the petitioner has met the burden of proof, analysis should initially focus on the best interests of the children. Determining what is in the best interests of children requires an evaluation of numerous factors. (See D’Onofrio v. D’Onofrio (1976), 144 N.J. Super. 200, 365 A.2d 27.) The appellate majority, however, held that its reading of case law regarding the burden of proof to be borne by the parent seeking removal of a minor child indicated a trend which would permit removal unless rather strong negative circumstances indicated against it. The appellate majority found that a prima facie showing is made when a proper custodian states a desire to remove, shows a sensible reason for the move, and makes at least a superficial showing that the move is consistent with the child’s best interest. (See also In re Marriage of Burgham (1980), 86 Ill. App. 3d 341, 345-46.) Furthermore, it was noted that a child rarely receives any demonstrable benefit from moving, and therefore the petitioning spouse need not show a direct benefit. Accordingly, the appellate court found that the petitioner had made a prima facie showing, and that the father failed to establish that the child would suffer specific harm from the move and therefore the petition for removal should have been granted.

We disagree. The appellate majority’s standard is contrary to the express language of section 609 of the Illinois Marriage and Dissolution of Marriage Act (Ill. Rev. Stat. 1985, ch. 40, par. 609), which states that “the burden of proving that such removal is in the best interests of such child or children is on the party seeking the removal.” The test set out by the appellate majority dilutes the burden of proof which the legislature has placed on the custodial parent in the statute governing removal of children from this State. Ill. Rev. Stat. 1985, ch. 40, par. 609.

In deciding whether removal is in the child’s best interest, a trial court should hear any and all relevant evidence. (Cooper v. Cooper (1984), 99 N.J. 42, 76-77, 491 A.2d 606, 624 (Schreiber, J., concurring).) A determination of the best interests of the child cannot be reduced to a simple bright-line test, but rather must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case. (See, e.g., Dozier v. Dozier (1959), 167 Cal. App. 2d 714, 334 P.2d 957; Hale v. Hale (1981), 12 Mass. App. Ct. 812, 429 N.E. 2d 340.) There are, however, several factors which may aid a trial court in determining the best interests of the child. The court should consider the proposed move in terms of likelihood for enhancing the general quality of life for both the custodial parent and the children. (Gallagher v. Gallagher (1978), 60 Ill. App. 3d 26, 31; D’Onofrio v. D’Onofrio (1976), 144 N.J. Super. 200, 205-07, 365 A.2d 27, 30.) The court should also consider the motives of the custodial parent in seeking the move to determine whether the removal is merely a ruse intended to defeat or frustrate visitation. (See Winebright v. Winebright (1987), 155 Ill. App. 3d 722, 725; In re Custody of Arquilla (1980), 85 Ill. App. 3d 1090, 1093.) Similarly, the court should consider the motives of the noncustodial parent in resisting the removal. (D’Onofrio, 144 N.J. Super. at 206-07, 365 A.2d at 30.) It is also in the best interests of a child to have a healthy and close relationship with both parents, as well as other family members. Therefore, the visitation rights of the noncustodial parent should be carefully considered. (In re Marriage of Brady (1983), 115 Ill. App. 3d 521, 523; In re Marriage of Burgham (1980), 86 Ill. App. 3d 341, 346.) Another factor is whether, in a given case, a realistic and reasonable visitation schedule can be reached if the move is allowed. In re Custody of Anderson (1986), 145 Ill. App. 3d 746.

A reasonable visitation schedule is one that will preserve and foster the child’s relationship with the noncustodial parent. When a parent has assiduously exercised his or her visitation rights, “a court should be loath to interfere with it by permitting removal of the children for frivolous or unpersuasive or inadequate reasons.” (D’Onofrio, 144 N.J. Super. at 206, 467 A.2d at 30, citing Grove v. Grove (1953), 26 N.J. Super. 154, 97 A.2d 505.) However, if the best interests of the children would not be affected by a move to another State, the custodial parent should be free to move. Thus, if the noncustodial parent objects to the removal but has not exercised his or her visitation rights, this fact should be considered in determining whether to grant the custodial parent’s desire to move. Cooper v. Cooper (1984), 99 N.J. 42, 70, 491 A.2d 606, 620 (Schreiber, J., concurring).

When removal to a distant jurisdiction will substantially impair the noncustodial parent’s involvement with the child, the trial court should examine the potential harm to the child which may result from the move. (E.g., In re Marriage of Bednar (1986), 146 Ill. App. 3d 704, 711; In re Marriage of Burgham (1980), 86 Ill. App. 3d 341, 346.) Moreover, a trial court’s examination of a removal petition should be guided by the policy of the Illinois Marriage and Dissolution of Marriage Act in custody matters, which states, inter alia, that the purpose of the Act is to “secure the maximum involvement and cooperation of both parents regarding the physical, mental, moral and emotional well-being of the children during and after the litigation.” (Ill. Rev. Stat. 1986, ch. 40, par. 102(7); see also In re Marriage of Bednar (1986), 146 Ill. App. 3d 704, 711.) If the custodial parent, however, establishes a good, sincere reason for wanting to move to another jurisdiction, the trial court should consider all the relevant factors in determining the best interest of the child. (Yannas v. Frondistou-Yannas (1985), 395 Mass. 704, 711-12, 481 N.E.2d 1153, 1158.) A trial court’s determination of what is in the best interests of the child should not be reversed unless it is clearly against the manifest weight of the evidence and it appears that a manifest injustice has occurred. Quirin v. Quirin (1977), 50 Ill. App. 3d 785; Hickey v. Hickey (1975), 31 Ill. App. 3d 257.

In the present case, although Carol testified that she wished to move to advance her career and financial well-being, her new position in Yuma would pay little, if any, more than she is earning now. Moreover, the petitioner admitted on cross-examination that she really was not looking for work. Thus, petitioner’s claim that the move was motivated by desire to enhance her career is questionable.

Petitioner’s assertion that she cannot find comparable work is also questionable. Although the petitioner testified she would not be able to find employment at an accredited nursing program in the Belleville area, she admitted that she had not looked for work in the St. Louis area because it would not be feasible to commute from her Belleville home. In response to this assertion, we note that an appellate court in this State that was confronted with the same issue in a remarkably similar case, stated: “We fail to follow petitioner’s argument that it would be worth moving to Arizona to find a *** nursing position but not worth moving within the [St. Louis/Belleville] area to find a similar position.” See In re Custody of Anderson (1986), 145 Ill. App. 3d 746, 752.

The petitioner additionally alleged that the move to Arizona would improve her other son’s asthmatic condition. As the trial court noted, there was no evidence introduced on how the move to Yuma would affect Bernie’s asthma. (Cf. Hickey, 31 Illl App. 3d 257.) We are compelled to agree with the father that the petitioner failed to meet her burden of proof that the removal to Arizona would be in the best interests of the child. Moreover, there was evidence introduced establishing that Mark Eckert was “an exemplary parent” and that he had an exceptionally good relationship with his son. (148 Ill. App. 3d 512, 524 (Welch, J., dissenting).) Additionally, several witnesses testified that the petitioner did not cooperate with respondent regarding visitation. This was corroborated by Matthew, who told the trial judge in chambers that he was was not allowed to phone his father and did not understand why. Finally, most of Matthew’s extended family lives in the Belleville area, including all three of his surviving grandparents.

We conclude that the record supports the trial court’s order denying permission to remove the child to Arizona. “The trier of fact had significant opportunity to observe both parents and the child and, thus, is able to assess and evaluate their temperaments, personalities, and capabilities. We should not disturb the determination of the trial court unless it has resulted in manifest injustice or is against the manifest weight of the evidence. The presumption in favor of the result reached by the trial court is always strong and compelling in this type of case.” Gallagher v. Gallagher (1978), 60 Ill. App. 3d 26, 31-32.

We recognize that our society is a mobile one. (See Spencer v. Spencer (1971), 132 Ill. App. 2d 740, 743.) However, we decline to adopt the standard set out by the appeUate court because it substantially dilutes the burden of proof the legislature has placed on the custodial parent seeking to remove the child to another jurisdiction. We reiterate that the burden of proof is on the custodial parent to establish that the move, considering its possible impact on visitation, as well as all other relevant factors, would be in the child’s best interest.

We further conclude that the trial court did not err in denying an order authorizing the release of all information regarding the best interests of Matthew obtained by psychologist, Dr. Thomas Evans, who had counseled both parties. Initially, we note that without an offer of proof for the record, the reviewing court cannot determine the nature and significance of the excluded evidence (In re Marriage of Milovich (1982), 105 Ill. App. 3d 596, 610), and therefore, it is technically waived. Moreover, the petitioner has failed to provide any authority in support of this proposition. We note, finally, that while the testimony of a psychologist is generally acceptable to ascertain the best interests of the chüd, such testimony is not dispositive of the issue. (See In re Marriage of Auer (1980), 86 Ill. App. 3d 84; In re Marriage of Sieck (1979), 78 Ill. App. 3d 204.) We therefore find that the court did not abuse its discretion in denying an order authorizing the release of all information obtained by Dr. Thomas Evans. See generally In re Marriage of Semmler (1980), 90 Ill. App. 3d 649, 652.

We therefore reverse the judgment of the appellate court and affirm the judgment of the circuit court of St. Clair County denying the petition for removal.

Appellate court reversed; circuit court affirmed.

JUSTICE SIMON took no part in the consideration or decision of this case.