section 510(a) modification (Illinois) · Go Syfert
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section 510(a) modification in Illinois

18 Illinois opinions name it 2 courts 1984–2026 5 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
In Re Marriage of Davisgreen
illappct · 1997 · cited in 2 Illinois opinions naming this issue, 2020–2023
2 sentences

2023Then court then noted that is well-established in Illinois law that (1) a trial court has “indefinite jurisdiction” to enforce its judgments (In re Marriage of O’Malley, 2016 IL App (1st) 151118, ¶ 42 ) and (2) a modification occurs under section 510(b) of the Act when new obligations are engrafted onto a party under the order (In re Marriage of Davis, 292 Ill.

2020In re Marriage of Davis, 292 Ill.

22
In re Marriage of Kraftgreen
illappct · 1991 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., In re Marriage of Kraft, 217 Ill.App.3d 502 , 160 Ill.Dec. 392 , 577 N.E.2d 522 (1991).

2011See, e.g., In re Marriage of Kraft, 217 Ill.App.3d 502 , 160 Ill.Dec. 392 , 577 N.E.2d 522 (1991).

22
In Re Marriage of Mittragreen
illappct · 1983 · cited in 6 Illinois opinions naming this issue, 1984–2026
2 sentences

2026App. 3d at 770 (“The failure of the recipient to make good-faith efforts to achieve financial independence (e.g., to seek employment) can be the basis for a petition for modification pursuant to section 510(a).”); In re Marriage of Mittra, 114 Ill.

1987App. 3d 37, 41 , 465 N.E.2d 649, 652 .) Moreover, it has been said: “The failure of the petitioner to make good-faith efforts to achieve this goal, following a reasonable time frame during which the objective should be accomplished, might form the basis for a petition for modification pursuant to section 510(a) of the Act. [Citations.]” (In re Marriage of Mittra (1983), 114 Ill.

16
In Re Marriage of Pittsgreen
illappct · 1988 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See In re Marriage of Pitts, 169 Ill. App. 3d 200, 209-211 (1988) (ordering wife to pay a percentage of the mortgage constituted an impermissible modification where original judgment required husband to pay the mortgage in full until sold).

11
Blum v. Kostergreen
ill · 2009 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Blum v. Koster, 235 Ill. 2d 21, 35-36 (2009).

11
Nerini v. Nerinigreen
illappct · 1986 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020Nerini v. Nerini, 140 Ill.

11
In Re Marriage of Gunngreen
illappct · 1992 · cited in 1 Illinois opinions naming this issue, 2000–2000
2 sentences

2000Mittra, 114 Ill.App.3d at 635 , 71 Ill.Dec. 350 , 450 N.E.2d at 1234 ; In re Marriage of Gunn, 233 Ill.App.3d 165, 180 , 174 Ill.Dec. 381 , 598 N.E.2d 1013, 1023 (1992).

2000Mittra, 114 Ill.App.3d at 635 , 71 Ill.Dec. 350 , 450 N.E.2d at 1234 ; In re Marriage of Gunn, 233 Ill.App.3d 165, 180 , 174 Ill.Dec. 381 , 598 N.E.2d 1013, 1023 (1992).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Meyer v. Meyer green
illappct · 1991
2 sentences

2003It cites two cases holding that a parent’s obligation to pay child support ends, by operation of law, when the child abandons the parental home (Meyer v. Meyer, 222 Ill.

2003It cites two cases holding that a parent's obligation to pay child support ends, by operation of law, when the child abandons the parental home ( Meyer v. Meyer , 222 Ill.

22003–2003
In Re Marriage of Mayhall green
illappct · 2000
2 sentences

2000Mayhall , 311 Ill.

2000Mayhall, 311 Ill.

22000–2000
In re Marriage of O'Malley green
illappct · 2016
1 sentence

2023Then court then noted that is well-established in Illinois law that (1) a trial court has “indefinite jurisdiction” to enforce its judgments (In re Marriage of O’Malley, 2016 IL App (1st) 151118, ¶ 42 ) and (2) a modification occurs under section 510(b) of the Act when new obligations are engrafted onto a party under the order (In re Marriage of Davis, 292 Ill.

12023–2023
In re Marriage of Warner green
illappct · 2020
1 sentence

2022As we noted above, a modification occurs under section 510(b) of the Marriage Act (750 ILCS 5/510(b) (West 2018)) “when new obligations are engrafted onto a party under the order.” Warner, 2020 IL App (3d) 190198, ¶ 22 .

12022–2022
Conner v. Watkins green
illappct · 1987
2 sentences

2011Conner, 158 Ill.App.3d at 762 , 110 Ill.Dec. 365 , 511 N.E.2d 200 . ¶ 22 These cases establish that Illinois decisional law has since 1986 consistently regarded the actions taken pursuant to reservations clauses to be modifications under section 510 subject to the prohibition of retroactive support.

2011Conner, 158 Ill.App.3d at 762 , 110 Ill.Dec. 365 , 511 N.E.2d 200 . ¶ 22 These cases establish that Illinois decisional law has since 1986 consistently regarded the actions taken pursuant to reservations clauses to be modifications under section 510 subject to the prohibition of retroactive support.

12011–2011
In Re Marriage of Lasota green
illappct · 1984
1 sentence

1987App. 3d 37, 41 , 465 N.E.2d 649, 652 .) Moreover, it has been said: “The failure of the petitioner to make good-faith efforts to achieve this goal, following a reasonable time frame during which the objective should be accomplished, might form the basis for a petition for modification pursuant to section 510(a) of the Act. [Citations.]” (In re Marriage of Mittra (1983), 114 Ill.

11987–1987

Statutes the citing opinions construe

IL § 750 ILCS 5/510 (13) IL § 750 ILCS 5/504 (8) IL § 750 ILCS 5/505 (5) IL § 750 ILCS 5/513 (4) IL § 735 ILCS 5/2-1401 (3) IL § 750 ILCS 5/101 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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