Vance v. Joyner, 146 N.E.3d 285

2009: Paternity of M.J. (born 2006) was established; a July 2009 child-support order required Roderick Joyner to pay $55.49/week. Joyner largely stopped paying after July 2010. Rhonda Vance later sought modification and contempt relief.
2015 petition to modify child support alleged Roderick’s income increased; multiple hearings held in 2017–2018 after extensive discovery disputes and inconsistent financial disclosures by both parties.
Rhonda reported low wage income (~$24,850 in 2015) and monthly shortfalls; she received repeated financial assistance from her parents (gifts she did not list as income on her affidavit).
Roderick operates a cash-only barbershop, owns rental properties, submitted multiple inconsistent financial affidavits, testified to averaging net business income of ~$23,662/year, and had loan/financing documents showing $105,000 annual income; he also purchased a 2014 Cadillac.
Trial court found a substantial change in circumstances, set Roderick’s gross income at $6,000/month and monthly child support at $766.90 (later reduced to $760.03), found him in indirect civil contempt for unpaid arrears, excluded Rhonda’s parental gifts from her income as a deviation, and ordered Roderick to pay Rhonda’s attorney fees (~$15,014).
On appeal the Fourth District affirmed the income finding for Roderick and the attorney-fee award but reversed the exclusion of Rhonda’s parental gifts from her income and remanded for further proceedings.

Issue	Plaintiff's Argument (Vance)	Defendant's Argument (Joyner)	Held
Whether the trial court erred by excluding gifts Rhonda received from her parents when calculating her income	Gifts are loans or not income and thus should be excluded from Rhonda’s net income	Gifts are income (or loans in name only); the court must calculate both parents’ incomes the same way	Court: Gifts from parents constitute income for child-support purposes; exclusion without the statutorily required written deviation findings was an abuse of discretion — reversed and remanded
Whether the trial court erred in calculating Roderick’s income (setting gross at $6,000/month)	Rhonda argued court should include transfers/deposits and other indicia showing higher income	Roderick argued his income was lower, that the $105,000 loan application was misleading and his affidavits were accurate	Court: Given inconsistent, incomplete, and unreliable financial records, the trial court reasonably set income at $6,000/month as a reasonable amount — affirmed
Whether the trial court abused its discretion in ordering Roderick to pay Rhonda’s attorney fees	Rhonda sought fees showing inability to pay and attached affidavits; award appropriate under Parentage Act	Roderick argued procedural defects and that court failed to consider both parties’ ability to pay	Court: Trial court did not abuse discretion in awarding fees; petition for interim fees sufficed and record presumes court considered statutory factors — affirmed

In re Marriage of Rogers, 213 Ill.2d 129 (statutory definition of income includes gifts and recurrent benefits)
In re Marriage of Mayfield, 989 N.E.2d 601 (Ill. 2013) (significant gifts are income for child-support calculation)
In re Marriage of Tegeler, 365 Ill. App.3d 448 (loan proceeds are generally not income when repayment is intended)
In re Marriage of Baumgartner, 384 Ill. App.3d 39 (mortgage loan proceeds are not income where repayment was intended)
In re Marriage of Anderson, 938 N.E.2d 207 (Ill. App. 2010) (large, non‑repayable parent “loans” treated as income)
In re Marriage of Heroy, 89 N.E.3d 296 (Ill. 2017) (standards for awarding attorney fees; consider parties’ financial resources)
Foutch v. O’Bryant, 459 N.E.2d 958 (Ill. 1984) (appellant bears burden to present a sufficiently complete record; doubts resolved against appellant)