Illinois Appellate Court
Civil Court
Child Custody
Wife appealed court order awarding custody of parties' 3 children to husband, five years after court had awarded sole custody of 3 children to wife. Court found that significant developmental concerns had arisen in those 5 years, especially as to the older 2 children, and that strongest factor favoring changing custody to husband was wife's failure to facilitate and encourage a close and continuing relationship between children and their father. (ROCHFORD and DELORT, concurring.)