Department of Healthcare and Family Services v. Conner

Respondent appealed from a circuit court order denying his petition for a zero child support order, denying his motion to suspend child support arrearage payments, and denying his petition for injunctive relief. Respondent argued on appeal that the trial court erred by ruling that a means-tested concurrent Supplemental Security Income and Social Security Retirement benefit is not protected under the Illinois Marriage and Dissolution of Marriage Act, in denying his injunctive relief, in failing to give written findings for its deviation from statutory guidelines regarding a zero dollar support order, from declining to enjoin HFS from threatening to suspend his driver’s license, and in dismissing his petition for zero dollar child support by finding that it failed to allege that there had been a substantial change in circumstances in addition to receiving only means-tested assistance and inability to work due to a medically proven disability. The appellate court affirmed, finding that the trial court did not commit any errors. (CATES and VAUGHAN, concurring)