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14 Illinois opinions name it 1 courts 1997–2026 6 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.
| Case | Followed | Cited |
|---|---|---|
In Re Marriage of Diehlgreen2 sentences2026Section 603.10(a) provides: “After a hearing, if the court finds by a preponderance of the evidence that a parent engaged in any conduct that seriously endangered the child’s mental, moral, or physical health or that significantly impaired the child’s emotional development, the court shall enter orders as necessary to protect the child.” 750 ILCS 5/603.10(a) (West 2022). ¶ 27 “The serious-endangerment standard has been described as an ‘onerous, stringent, and rigorous’ burden to meet.” In re Marriage of Mayes, 2018 IL App (4th) 180149 , ¶ 56 (quoting In re Marriage of Diehl, 221 Ill. 2025The serious-endangerment standard of section 603.10 “has been described as an ‘onerous, stringent, and rigorous’ burden to meet.” In re Marriage of Mayes, 2018 IL App (4th) 180149, ¶ 56 (quoting In re Marriage of Diehl, 221 Ill. | 6 | 8 |
In re Marriage of Mayesgreen2 sentences2026See Mayes, 2018 IL App (4th) 180149, ¶ 56 (the serious-endangerment standard has been described as an “onerous, stringent, and rigorous” burden to meet (internal quotation marks omitted)). 2026Section 603.10(a) provides: “After a hearing, if the court finds by a preponderance of the evidence that a parent engaged in any conduct that seriously endangered the child’s mental, moral, or physical health or that significantly impaired the child’s emotional development, the court shall enter orders as necessary to protect the child.” 750 ILCS 5/603.10(a) (West 2022). ¶ 27 “The serious-endangerment standard has been described as an ‘onerous, stringent, and rigorous’ burden to meet.” In re Marriage of Mayes, 2018 IL App (4th) 180149 , ¶ 56 (quoting In re Marriage of Diehl, 221 Ill. | 4 | 4 |
In Re Marriage of Andersongreen2 sentences2014App. 3d 651, 658 (1998). ¶ 32 Section 607(c) of the Marriage Act provides: “The court may modify an order granting or denying visitation rights of a parent whenever modification would serve the best interests of the child; but the court shall not restrict a parent’s visitation rights unless it finds that the visitation would endanger seriously the child’s physical, mental, moral[,] or emotional health.” 750 ILCS 5/607(c) (West 2012). ¶ 33 A visitation restriction, thus, must meet the serious-endangerment standard, which is more onerous than the best-interests standard (which governs the modifi 2014App. 3d 651, 658 (1998). ¶ 32 Section 607(c) of the Marriage Act provides: “The court may modify an order granting or denying visitation rights of a parent whenever modification would serve the best interests of the child; but the court shall not restrict a parent’s visitation rights unless it finds that the visitation would endanger seriously the child’s physical, mental, moral[,] or emotional health.” 750 ILCS 5/607(c) (West 2012). ¶ 33 A visitation restriction, thus, must meet the serious-endangerment standard, which is more onerous than the best-interests standard (which governs the modifi | 2 | 2 |
In Re Marriage of Leegreen2 sentences2005In re Marriage of Lee, 246 Ill. 2005In re Marriage of Lee , 246 Ill. | 2 | 2 |
Crichton v. Crichtongreen2 sentences1997Crichton v. Crichton, 75 Ill.App.3d 326, 329-30 , 31 Ill.Dec. 12, 14-15 , 393 N.E.2d 1319, 1321-22 (1979), citing Blazina v. Blazina, 42 Ill. 1997Crichton v. Crichton, 75 Ill. | 1 | 2 |
Heldebrandt v. Heldebrandtgreen1 sentence2024Another appellate decision remarked that the court’s determination of serious endangerment is an “extraordinary finding.” Heldebrandt v. Heldebrandt, 251 Ill. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re Parentage of K.E.B.
green
1 sentence2014We concluded that the trial court applied the best-interests standard when it should have applied the serious-endangerment standard and that it “failed to specifically find that Christine’s condition and behavior posed a danger to K.E.B.” Id. | 1 | 2014–2014 |
Blazina v. Blazina
green
1 sentence1997Crichton v. Crichton, 75 Ill.App.3d 326, 329-30 , 31 Ill.Dec. 12, 14-15 , 393 N.E.2d 1319, 1321-22 (1979), citing Blazina v. Blazina, 42 Ill. | 1 | 1997–1997 |
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.