In re Marriage of Knoll

Illinois Appellate Court
Civil Court
Visitation
Citation
Case Number: 
2016 IL App (1st) 152494
Decision Date: 
Friday, September 30, 2016
District: 
1st Dist.
Division/County: 
Cook Co., 5th Div.
Holding: 
Vacated in part and affirmed in part.
Justice: 
GORDON

Court found Petitioner in civil contempt for depriving Respondent of his visitation rights with their minor child following dissolution of parties' marriage. Court determined that husband was denied his visitation instead of voluntarily electing to forego it, as wife contended. Court's civil contempt order was invalid as it did not contain a purge provision, or set forth conditions upon which wife may dissolve indirect civil contempt. Court properly found that, under Section 607.1 of Dissolution of Marriage Act, wife had committed visitation abuse for 2 days, and court properly ordered make-up visitation for periods of time in which husband was unable to exercise his parenting time, which is a remedy expressly authorized by statute.(HALL and REYES, concurring.)