In re Marriage of Larsen

Respondent in a post-judgment dissolution of marriage proceedings filed a petition to terminate monthly maintenance payments to his former spouse on the basis that she was cohabiting in a manner that constituted a de facto marriage under the Illinois Marriage and Dissolution of Marriage Act. The trial court denied the petition and respondent appealed, arguing that the trial court order was against the manifest weight of the evidence. The appellate court affirmed, finding that the trial court’s was not unreasonable or arbitrary where the evidence established that petitioner was in an intimate dating relationship but that it did not amount to a de facto marriage. (McBRIDE and ELLIS, concurring)