79 Illinois opinions name it 2 courts 1981–2026 35 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 |
|---|---|---|
Young v. Hermangreen2 sentences2025Though 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 App (4th) 170 2025We therefore decline Zachary’s invitation to reverse the parenting time decision and remand the matter for a new hearing. ¶ 65 We reiterate that “ ‘[i]n 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, 2018 IL App (4th) 170001, ¶ 64 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ). | 9 | 14 |
In re Marriage of Agersgreen2 sentences2026In these types of 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[ren].’ ” Jameson, 2020 IL App (3d) 200048, ¶ 50 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see also In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988). 2026In these types of 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[ren].’ ” Jameson, 2020 IL App (3d) 200048, ¶ 50 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see also In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988). | 6 | 23 |
Jameson v. Williamsgreen2 sentences2026In these types of 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[ren].’ ” Jameson, 2020 IL App (3d) 200048, ¶ 50 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see also In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988). 2026In these types of 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[ren].’ ” Jameson, 2020 IL App (3d) 200048, ¶ 50 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see also In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988). | 5 | 9 |
In Re Marriage of Eckertgreen2 sentences2026In these types of 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[ren].’ ” Jameson, 2020 IL App (3d) 200048, ¶ 50 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see also In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988). 2026In these types of 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[ren].’ ” Jameson, 2020 IL App (3d) 200048, ¶ 50 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see also In re Marriage of Eckert, 119 Ill. 2d 316, 330 (1988). | 4 | 12 |
In re Marriage of Dorfmangreen2 sentences2017“There is a strong and compelling presumption in favor of the result reached by the trial court in a removal case.” In re Marriage of Dorfman, 2011 IL App (3d) 110099, ¶ 52 (citing Eckert, 119 Ill. 2d at 330 ). 2017“There is a strong and compelling presumption in favor of the result reached by the trial court in a removal case.” In re Marriage of Dorfman, 2011 IL App (3d) 110099, ¶ 52 (citing Eckert, 119 Ill. 2d at 330 ). | 4 | 5 |
In Re Marriage of Spanglergreen2 sentences2025Though 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 App (4th) 170 2024See 750 ILCS 5/602.7(b) (West 2022). ¶ 48 In parenting time modification cases like this, “ ‘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 App (4th) 170001, ¶ 64 , 92 N.E.3d 1070 (quoting Agers, 2013 IL App (5th) 120375, ¶ 25 ); see In re Marriage of Spangler, 124 Ill. | 3 | 3 |
In Re Marriage of Jerome and Martinezgreen2 sentences2025In re Marriage of Jerome, 255 Ill. 2001See In re Marriage of Jerome, 255 Ill. | 3 | 3 |
In re Jordyn L.green2 sentences2025See In re Jordyn L., 2016 IL App (1st) 150956, ¶ 29 (noting the strong and compelling presumption in favor of the result determined by the trial court in child custody cases). ¶ 53 B. 2024See Jordyn L., 2016 IL App (1st) 150956, ¶ 29 (noting the strong and compelling presumption in favor of the result determined by the circuit court in child custody cases). ¶ 51 CONCLUSION ¶ 52 For the reasons discussed above, the findings of abuse and neglect were not against the manifest weight of the evidence. | 2 | 4 |
In Re Custody of Sussenbachgreen2 sentences2023See In re -8- Custody of Sussenbach, 108 Ill. 2d 489, 499 , 485 N.E.2d 367, 371 (1985) (“[T]he trial court is in the best position to judge the credibility of the witnesses and determine the needs of the child.”). “ ‘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 App (4th) 170001, ¶ 64 , 92 N.E.3d 1070 (quoting In re Marriage of Agers, 2013 IL App (5th) 120375, ¶ 25 , 991 N.E.2d 944 ). ¶ 2023See In re Custody of Sussenbach, 108 Ill. 2d 489, 499 (1985). “ ‘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 the superior position to evaluate the evidence and determine the best interests of the child.’ ” Young v. Herman, 2018 IL App (4th) 170001, ¶ 64 (quoting In re Marriage of Agers, 2013 IL App (5th) 120375, ¶ 25 ). ¶ 35 A trial court’s determination regarding allocation of decision-making will not be reversed unless the decision is against the manifest weight of the evidence. | 2 | 2 |
People v. Phillipsgreen2 sentences2012See People v. Phillips, 392 Ill.App.3d 243 , 331 Ill.Dec. 641 , 911 N.E.2d 462 (2009). 2012See People v. Phillips, 392 Ill.App.3d 243 , 331 Ill.Dec. 641 , 911 N.E.2d 462 (2009). | 2 | 2 |
In Re Marriage of Diehlgreen2 sentences2006In re Marriage of Diehl, 221 Ill.App.3d 410, 424 , 164 Ill. 2006In re Marriage of Diehl, 221 Ill. | 2 | 2 |
In Re Marriage of Dotygreen2 sentences2005In re Marriage of Doty, 255 Ill. 2005In re Marriage of Doty , 255 Ill. | 2 | 2 |
In Re Marriage of Wrightgreen2 sentences1997App. 3d 392, 395 , 571 N.E.2d 197 (1991) ("There is a strong and compelling presumption that the trial court, the entity closest to the litigation and in the best position to observe the witnesses, has made the proper *** decision”). 1997App. 3d 392, 395 , 571 N.E.2d 197 (1991) ("There is a strong and compelling presumption that the trial court, the entity closest to the litigation and in the best position to observe the witnesses, has made the proper *** decision"). | 1 | 3 |
People v. Dorothy H.green1 sentence2026Indeed, in child custody cases, “‘there is a strong and compelling presumption in favor of the result reached by the trial court.’” Id. (quoting In re William H., 407 Ill. | 1 | 1 |
People v. Alyssa G. (In Re J v.green1 sentence2026“There is a strong and compelling presumption in favor of the result reached by the trial court in child custody cases.” Id. - 23 - No. 1-25-1072 ¶ 61 For the best interest determination, “the parent’s interest in maintaining the parent-child relationship must yield to the child’s interest in a stable, loving home life.” In re J.V., 2018 IL App (1st) 171766, ¶ 249 (citing In re Curtis W., Jr., 2015 IL App (1st) 143860, ¶ 52 ). | 1 | 1 |
| In re Marriage of Jessica F.green | 1 | 1 |
| In Re Marriage of Pfeiffergreen | 1 | 1 |
| Roth v. Illinois Farmers Ins. Co.green | 1 | 1 |
| Bright v. Dickegreen | 1 | 1 |
| Marcus v. Marcusgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sadler v. Pulliam
neutral
2 sentences2026We will not overturn the circuit court’s decision “unless the court abused its considerable discretion or its decision is against the manifest weight of the evidence.” Sadler v. Pulliam, 2022 IL App (5th) 220213, ¶ 42 . 2025“We will not overturn the court’s decision unless the court abused its considerable discretion or its decision is against the manifest weight of the evidence.” Sadler v. Pulliam, 2022 IL App (5th) 220213, ¶ 42 . | 3 | 2023–2026 |
In re Marriage of Fatkin
green
2 sentences2026Fatkin, 2019 IL 123602, ¶ 32 . 2025Id. 12 ¶ 34 Section 609.2(g) of the Illinois Marriage and Dissolution of Marriage Act sets forth the factors for consideration when determining relocation requests. 750 ILCS 5/609.2(g) (West 2024). | 3 | 2021–2026 |
In re Marriage of Young
neutral
2 sentences2018"We will not disturb a trial court's custody determination unless it is against the manifest weight of the evidence." Young , 2015 IL App (3d) 150553 , ¶ 12, 400 Ill.Dec. 146 , 47 N.E.3d 1111 . 2018"We will not disturb a trial court's custody determination unless it is against the manifest weight of the evidence." Young , 2015 IL App (3d) 150553 , ¶ 12, 400 Ill.Dec. 146 , 47 N.E.3d 1111 . | 3 | 2018–2018 |
In Re Marriage of Willis
green
2 sentences2009In re Marriage of Willis, 234 Ill. 2009In re Marriage of Willis, 234 Ill.App.3d at 161 , 174 Ill.Dec. 633 , 599 N.E.2d at 183 . | 3 | 1994–2009 |
Verhines v. Hickey (In Re Verhines)
green
2 sentences2023Jameson, 2020 IL App (3d) 200048, ¶ 47 ; In re Custody of G.L., 2017 IL App (1st) 163171, ¶ 24 , 80 N.E.3d 636 . ¶ 41 “Under the manifest weight standard, an appellate court will affirm the trial court’s ruling if there is any basis in the record to support the trial court’s findings.” Id. ¶ 24. “ ‘A decision is against the manifest weight of the evidence when an opposite conclusion is apparent or when the court’s findings appear to be unreasonable, arbitrary, or not based on evidence.’ ” Jameson, 2020 IL App (3d) 200048, ¶ 47 (quoting In re Marriage of Verhines, 2018 IL App (2d) 171034, ¶ 51 2023“A decision is against the manifest weight of the evidence when an opposite conclusion is apparent or when the court's findings appear to be unreasonable, arbitrary, or not based on evidence.” In re Marriage of Verhines, 2018 IL App (2d) 171034, ¶ 51 . ¶ 54 “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 16 the best interests of the child.” In re Marriage of Agers, 2013 IL App (5th) 120375, ¶ 25 . | 2 | 2023–2023 |
In re Nicholas C.
green
2 sentences2023Id. ¶ 31 But while we are deferential to the trial court, we must be mindful that the right of a -8- No. 1-22-1216 parent to the care, custody and companionship of their children is perhaps one of the oldest fundamental liberty interests. 2023Id. ¶ 32 But while we are deferential to the trial court, we must be mindful that the right of a parent to the care, custody and companionship of their children is perhaps one of the oldest fundamental liberty interests. | 2 | 2023–2023 |
In re Custody of G.L.
green
2 sentences2023Jameson, 2020 IL App (3d) 200048, ¶ 47 ; In re Custody of G.L., 2017 IL App (1st) 163171, ¶ 24 , 80 N.E.3d 636 . ¶ 41 “Under the manifest weight standard, an appellate court will affirm the trial court’s ruling if there is any basis in the record to support the trial court’s findings.” Id. ¶ 24. “ ‘A decision is against the manifest weight of the evidence when an opposite conclusion is apparent or when the court’s findings appear to be unreasonable, arbitrary, or not based on evidence.’ ” Jameson, 2020 IL App (3d) 200048, ¶ 47 (quoting In re Marriage of Verhines, 2018 IL App (2d) 171034, ¶ 51 2023Jameson, 2020 IL App (3d) 200048, ¶ 47 ; In re Custody of G.L., 2017 IL App (1st) 163171, ¶ 24 , 80 N.E.3d 636 . ¶ 41 “Under the manifest weight standard, an appellate court will affirm the trial court’s ruling if there is any basis in the record to support the trial court’s findings.” Id. ¶ 24. “ ‘A decision is against the manifest weight of the evidence when an opposite conclusion is apparent or when the court’s findings appear to be unreasonable, arbitrary, or not based on evidence.’ ” Jameson, 2020 IL App (3d) 200048, ¶ 47 (quoting In re Marriage of Verhines, 2018 IL App (2d) 171034, ¶ 51 | 2 | 2022–2023 |
In Re Marriage of Smith
green
2 sentences2002There is a strong and compelling presumption in favor of a trial court's ruling because it "had significant opportunity to observe the parents and the children, thereby evaluating their temperaments, personalities, and capabilities." Smith , 172 Ill. 2d at 321 , 665 N.E.2d at 1213 . 2002There is a strong and compelling presumption in favor of a trial court's ruling because it "had significant opportunity to observe the parents and the children, thereby evaluating their temperaments, personalities, and capabilities." Smith , 172 Ill. 2d at 321 , 665 N.E.2d at 1213 . | 2 | 2002–2002 |
In Re Marriage of MacAluso
neutral
2 sentences1986App. 3d 838, 843 , 443 N.E.2d 1, 4 .) The trial court has broad discretion in awarding custody, and there is a strong and compelling presumption in its favor. ( 110 Ill. 1986App. 3d 838, 843 , 443 N.E.2d 1, 4 .) The trial court has broad discretion in awarding custody, and there is a strong and compelling presumption in its favor. ( 110 Ill. | 2 | 1986–1993 |
In Re Marriage of Stuart
green
2 sentences1989Just as there is a strong and compelling presumption in favor of the trial court’s determination of custody (In re Marriage of Stuart (1982), 141 Ill. 1989App. 3d 314 , 490 N.E.2d 243 ), so, too, we find a strong and compelling presumption in favor of the trial court’s determination to place E.J. with the Department incommunicado. | 2 | 1986–1989 |
In Re Marriage of Rizzo
green
2 sentences1985(See In re Marriage of Rizzo (1981), 95 Ill. 1985(In re Marriage of Rizzo (1981), 95 Ill. | 2 | 1985–1985 |
People v. Ernie C.
green
1 sentence2026Indeed, in child custody cases, “‘there is a strong and compelling presumption in favor of the result reached by the trial court.’” Id. (quoting In re William H., 407 Ill. | 1 | 2026–2026 |
In re M.J.
neutral
1 sentence2026“There is a strong and compelling presumption in favor of the result reached by the trial court in child custody cases.” Id. - 23 - No. 1-25-1072 ¶ 61 For the best interest determination, “the parent’s interest in maintaining the parent-child relationship must yield to the child’s interest in a stable, loving home life.” In re J.V., 2018 IL App (1st) 171766, ¶ 249 (citing In re Curtis W., Jr., 2015 IL App (1st) 143860, ¶ 52 ). | 1 | 2026–2026 |
In re Tajannah O.
green
1 sentence2026Id. ¶ 85 Section 1-3(4.05) of the Act lists 10 best interest factors with subfactors that the trial court should consider in the context of the children’s age and developmental needs when determining the children’s best interest. 705 ILCS 405/1-3(4.05)(a)-(j) (West 2024). | 1 | 2026–2026 |
In re Curtis W.
green
1 sentence2026“There is a strong and compelling presumption in favor of the result reached by the trial court in child custody cases.” Id. - 23 - No. 1-25-1072 ¶ 61 For the best interest determination, “the parent’s interest in maintaining the parent-child relationship must yield to the child’s interest in a stable, loving home life.” In re J.V., 2018 IL App (1st) 171766, ¶ 249 (citing In re Curtis W., Jr., 2015 IL App (1st) 143860, ¶ 52 ). | 1 | 2026–2026 |
| Jameson v. Williams green | 1 | 2022–2022 |
| In Re Marriage of Simmons green | 1 | 2013–2013 |
| In Re Marriage of Kennedy green | 1 | 1994–1994 |
| In Re Marriage of Hazard green | 1 | 1994–1994 |
| In Re Marriage of Benevento green | 1 | 1993–1993 |
| In Re Marriage of Slavenas green | 1 | 1992–1992 |
| In Re Custody of Piccirilli neutral | 1 | 1992–1992 |
| Cooper v. Cooper green | 1 | 1991–1991 |
| In Re Marriage of Pool green | 1 | 1991–1991 |
| Brooks v. Brooks neutral | 1 | 1991–1991 |
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.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.