In re Parentage of A.H.

Petitioner filed an action seeking to enforce and modify a child support order entered by a court in Thailand against the respondent, an Illinois resident, and the father of the petitioner’s minor children. The circuit court entered an order ordering the payment of past due child support, that respondent place funds into trust for prospective child support, pay retroactive modified child support, pay attorney fees and costs, and pay sanctions under SCR 137. Respondent appealed and the appellate court affirmed in part, reversed in part, vacated in part, and remanded for further proceedings. The appellate court held that the trial court was authorized under the principles of comity and under the Marriage Act and Parentage Act to consider and adjudicate the petition to modify the Thai judgment and that the Support Act did not prevent it from doing so. The appellate court also found that the record demonstrated a substantial change in circumstances that warranted modification of the Thai judgment and that the amount awarded by the trial court was not an abuse of discretion. The appellate court reversed the circuit court’s order that denied respondent’s claim for child support credit, finding that it could not calculate the correct amount of the credit from the record on appeal. The appellate court also vacated the portion of the order pertaining to the creation of the trust as well as the imposition of sanctions. (HOFFMAN, concurring and LAMPKIN, specially concurring in part and dissenting in part)