In re Marriage of Wengielnik, 146 N.E.3d 743

Matthew and Denise divorced in 2013 and entered a joint parenting agreement; Matthew had 82 overnights in 2016.
In December 2016 a new allocation/judgment increased Matthew’s parenting time to 130 overnights in odd years and 148 in even years (averaging a ~15% increase between years).
In October 2017 Matthew petitioned to modify child support, asserting the increased parenting time was a substantial change in circumstances warranting reduction.
At the August 2018 hearing Matthew was the only witness and submitted a calendar showing overnights; he presented no financial evidence about increased costs to him, decreased costs to Denise, or changed needs of the child.
The trial court granted Denise’s motion for a directed finding, holding that a change in parenting time alone, without evidence of monetary impact or changed child needs, does not constitute the requisite substantial change in circumstances for modifying child support.
Matthew appealed; the appellate court reviewed whether the trial court’s no-substantial-change finding was against the manifest weight of the evidence and affirmed.

Issue	Plaintiff's Argument (Denise)	Defendant's Argument (Matthew)	Held
Whether an increase in parenting time alone constitutes a "substantial change in circumstances" to modify child support	Denied; petitioner argued Matthew failed to show monetary impact or changed child needs	Increased parenting time (≈15% avg) inherently presumes increased expenses and therefore should be a substantial change without further financial proof	Affirmed: change in parenting time alone, without evidence of changed financial circumstances or child needs, is insufficient to modify child support; trial court’s finding was not against the manifest weight of the evidence

In re Marriage of Garrett, 336 Ill. App. 3d 1018 (discusses standard of review when modification is granted or denied)
In re Marriage of Barnard, 283 Ill. App. 3d 366 (review standard when trial court finds no substantial change)
City of Champaign v. Torres, 214 Ill. 2d 234 (appellate court may affirm for any reason apparent in the record)
In re Marriage of Adams, 348 Ill. App. 3d 340 (describes requirement to show increase in noncustodial parent's ability to pay and increase in child's needs)
In re Marriage of Turrell, 335 Ill. App. 3d 297 (same: petitioner must show increase in child's needs and supporting spouse's ability to pay)
In re Marriage of White, 204 Ill. App. 3d 579 (custody/parenting-time changes can, in some circumstances, constitute a substantial change)
In re Marriage of Singleteary, 293 Ill. App. 3d 25 (equitable changes in any relevant circumstances may justify modification)
Bragdon v. Abbott, 524 U.S. 624 (judicial construction of statutory language is presumed incorporated when language is repeated)
In re Marriage of Rash, 406 Ill. App. 3d 381 (child support modification must be decided on facts and circumstances of each case)