In re Marriage of Mayfield, 989 N.E.2d 601

Mayfield and Dykes married in 1995 and had two children; they divorced in 2003 with Dykes as custodial parent.
In 2011, Dykes petitioned to modify child support after Zachary reached the age of majority; Mayfield testified about a 2007 workplace injury and a 2010 lump-sum workers’ compensation settlement of $300,000 (net $239,920) that was prorated over his life expectancy.
The settlement stated it would be the equivalent of monthly payments for 34 years, amounting to $580.30 per month, and Mayfield’s pre-injury income was about $969.60 weekly.
Mayfield used the lump sum to pay mortgages, loans, property, vacations, and home remodeling; he did not notify Dykes about the workers’ comp claim or settlement.
The trial court ordered Mayfield to pay 20% of the entire lump-sum settlement as child support, plus monthly support based on pension disability funds; the appellate court affirmed, and the supreme court affirmed the decision.
Illinois Supreme Court held that lump-sum workers’ compensation settlements are income for child support, and that the apportionment of such settlements must be supported by evidence of deviation from guidelines; Wolfe was overruled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a lump-sum workers’ compensation settlement is income for child support.	Mayfield: lump-sum should be treated differently and not as ordinary income.	Dykes: Dodds correctly treats lump-sum as income for support calculations.	Yes; lump-sum is income.
Whether the court may apportion a lump-sum settlement to meet child-support needs.	Mayfield: allocate 20% only of prorated monthly amount, not entire lump sum.	Dykes: allocate 20% of the lump sum as support is proper.	Apportionment must be supported by evidence; 20% of lump sum upheld absent evidence of deviation.
Whether deviation from the guideline amount was proper given the lump-sum nature.	Mayfield: deviation warranted to reflect disability and limited future income; use prorated amount.	Dodds/Dissolution Act guidelines apply; deviation requires evidence; none shown.	No deviation evidenced; guidelines applied.
Whether Wolfe was correctly decided or should be overruled.	Mayfield argues Wolfe should allow deviations from 20% of future-wage portion.	Wolfe wrongly decided; it should be overruled as to allocation of lump sums.	Wolfe overruled; allocate per Dodds framework and evidence-based deviation.

In re Marriage of Dodds, 222 Ill. App. 3d 99 ((1991)) (lump-sum workers’ compensation is income for child support)
In re Marriage of Schacht, 343 Ill. App. 3d 348 ((2003)) (supports use of Dodds framework for income treatment)
In re Marriage of Wolfe, 298 Ill. App. 3d 510 ((1998)) (overruled; deviation framework misapplied in allocation of lump sums)
In re Rogers, 213 Ill. 2d 129 ((2004)) (gifts/loans can constitute income; future continuity relevant to deviation)
Cassens Transport Co. v. Illinois Industrial Comm’n, 218 Ill. 2d 519 ((2006)) (income includes workers’ compensation under statutory framework)
In re Marriage of McGrath, 2012 IL 112792 ((2012)) (guideline framework for determining child-support amounts)