68 Illinois opinions name it 2 courts 1988–2026 24 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 Eckertgreen2 sentences2026Determination 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 . 2025The court’s determination of what constitutes the children’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.” Id. at 326 . | 27 | 64 |
In re Marriage of Fatkingreen2 sentences2025As this Court recently noted in Kenney, 15 No. 1-25-0039 our supreme court has made clear that relocation determinations “ ‘ “cannot be reduced to a simple bright-line test.” ’ ” Kenney, 2023 IL App (1st) 221558, ¶ 57 (quoting Fatkin, 2019 IL 123602, ¶ 32 (quoting Eckert, 119 Ill. 2d at 326 )). 2025A 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)). | 5 | 11 |
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 2021Though 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.’ ” Young v. H | 2 | 2 |
In re Marriage of Kavchakgreen2 sentences2026Determination 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 . 2026Determination 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 . | 1 | 4 |
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 2021Though 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.’ ” Young v. H | 1 | 2 |
In re Marriage of Kenneygreen2 sentences2025As this Court recently noted in Kenney, 15 No. 1-25-0039 our supreme court has made clear that relocation determinations “ ‘ “cannot be reduced to a simple bright-line test.” ’ ” Kenney, 2023 IL App (1st) 221558, ¶ 57 (quoting Fatkin, 2019 IL 123602, ¶ 32 (quoting Eckert, 119 Ill. 2d at 326 )). 2025Rather, precisely because the child’s best interest is involved, relocation decisions “ ‘ “must be made on a case-by-case basis, depending, to a great extent, upon the circumstances of each case.” ’ ” Kenney, 2023 IL App (1st) 221558, ¶ 57 (quoting Fatkin, 2019 IL 123602, ¶ 32 (quoting Eckert, 119 Ill. 2d at 326 )); accord Kimberly R., 2021 IL App (1st) 201405 , ¶ 74. | 1 | 1 |
Cooper v. Coopergreen2 sentences1988(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. 1988(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. | 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 Rogan M.
green
2 sentences2017See 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). 2017See 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). | 4 | 2017–2017 |
In re Parentage of P.D.
green
2 sentences2017See 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). 2017See 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). | 3 | 2017–2017 |
In re Marriage of Agers
green
2 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 2021Though 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.’ ” Young v. H | 2 | 2021–2025 |
Gallagher v. Gallagher
green
1 sentence2024Id. ¶ 24 Relocation determinations also “ ‘cannot be reduced to a simple bright-line test.’ ” Fatkin, 2019 IL 123602, ¶ 32 (quoting Eckert, 119 Ill. 2d at 326 ). | 1 | 2024–2024 |
In Re Marriage of Bhati and Singh
green
2 sentences2021We also note “[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.” Bhati, 397 Ill. 2021App. 3d at 60-61 , 920 N.E.2d at 1153 . ¶ 39 This court gives great deference to a circuit court’s findings regarding the child’s - 14 - best interests because that court has the better position to observe the parties’ temperaments and personalities and assess the witnesses’ credibility. | 1 | 2021–2021 |
In re Marriage of Levites
green
1 sentence2021Id. ¶ 32; Eckert, 119 Ill. 2d at 326 ; Kavchak, 2018 IL App (2d) 170853, ¶ 65 . - 36 - 2021 IL App (2d) 200552 This suggests that other relocation cases are of limited value for purposes of comparison because the result in each case depends on the unique facts and circumstances of the case. | 1 | 2021–2021 |
In Re Marriage of Zamarripa-Gesundheit
green
1 sentence1992“These factors are: (1) the likelihood of enhancing the general quality of life for both the custodial parent and the child by allowing the move; (2) the motives of both parents: the motive of the custodial parent in seeking removal and the motive of the noncustodial parent in resisting the removal; and (3) the visitation rights of the noncustodial parent, which involves a determination of whether a realistic and reasonable visitation schedule can be reached if the move is allowed.” (In re Marriage of Zamarripa-Gesundheit (1988), 175 Ill. | 1 | 1992–1992 |
Dozier v. Dozier
green
2 sentences1988(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. 1988(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. | 1 | 1988–1988 |
Hale v. Hale
green
2 sentences1988(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. 1988(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. | 1 | 1988–1988 |
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.