In re Marriage of Patel

Illinois Appellate Court
Civil Court
Child Support
Citation
Case Number: 
2025 IL App (3d) 240453
Decision Date: 
Wednesday, December 3, 2025
District: 
3d Dist.
Division/County: 
DuPage Co.
Holding: 
Affirmed.
Justice: 
BERTANI

Petitioner appealed from a circuit court decision modifying the court's original child support order so that petitioner was required to pay additional child support. On appeal, petitioner argued that the trial court erred in finding that the parties’ agreement in the marital settlement agreement to cap petitioner’s income was voidable and that the trial court abused its discretion in setting the modified dollar amount. The appellate court affirmed, finding that the trial court did not err when it found it was not bound by the income cap in the MSA, that there was a sufficient change in circumstances to justify modification and that the evidence supported a conclusion that the amount set by the court was reasonable. (HETTEL and ANDERSON, concurring)