Illinois Appellate Court
Civil Court
Maintenance
Respondent appealed from a circuit court order denying his second petition to terminate maintenance, which alleged that his former spouse was engaged in a de facto marriage. The appellate court reversed finding the totality of the circumstances, including the length of the relationship, joint travel, cohabitation, and an exchange of rings, supported a finding of the existence of a de facto marriage and that the trial court’s order denying the respondent's petition was against the manifest weight of the evidence. (DAUGHERITY and HOLDRIDGE, concurring.)