In re Marriage of Razzano

Illinois Appellate Court
Civil Court
Child Support
Citation
Case Number: 
2012 IL App (3d) 110608
Decision Date: 
Wednesday, November 14, 2012
District: 
3d Dist.
Division/County: 
Iroquois Co.
Holding: 
Affirmed.
Justice: 
CARTER
Court properly used guidelines in Section 505(a) to modify husband's child support obligation, rather than Section 513(a)(2). Modification of parties' separation agreement, via handwritten note, indicated parties agreed to redefine "child support" to include post-secondary-education expenses, rather than reserving issue for future determination. As agreement was incorporated into judgment of dissolution, it was an enforceable order of the court. (LYTTON, concurring; McDADE, concurring in part and dissenting in part.)