In re Marriage of Hodges

Illinois Appellate Court
Civil Court
Child Support
Citation
Case Number: 
2018 IL App (5th) 170164
Decision Date: 
Tuesday, April 24, 2018
District: 
5th Dist.
Division/County: 
Clinton Co.
Holding: 
Affirmed.
Justice: 
GOLDENHERSH

Court entered order reducing child support arrearage of Respondent husband, and properly applied principles of equitable estoppel as basis for order. Petitioner induced Respondent to rely to his detriment on an agreement, reached at courthouse in 2006, to reduce child support to $165 per week; and Respondent's reliance was reasonable. Court did not err in finding Petitioner equitably estopped from collecting delinquent support payments from Respondent from date of her verbal agreement with Respondent until she initiated enforcement proceedings in 2014. (WELCH and MOORE, concurring.)