In re Marraige of Williams

2026 IL App (5th) 241260
CourtAppellate Court of Illinois
DecidedMarch 20, 2026
Docket5-24-1260
StatusPublished

This text of 2026 IL App (5th) 241260 (In re Marraige of Williams) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Marraige of Williams, 2026 IL App (5th) 241260 (Ill. Ct. App. 2026).

Opinion

NOTICE 2026 IL App (5th) 241260 Decision filed 03/20/26. The text of this decision may be NO. 5-24-1260 changed or corrected prior to the filing of a Petition for IN THE Rehearing or the disposition of the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

In re MARRIAGE OF ) Appeal from the ) Circuit Court of ABIGAIL WILLIAMS, ) Crawford County. ) Petitioner-Appellee, ) ) and ) No. 23-DC-21 ) JEREMY WILLIAMS, ) Honorable ) Matthew J. Hartrich, Respondent-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE SHOLAR delivered the judgment of the court, with opinion. Presiding Justice Cates and Justice Vaughan concurred in the judgment and opinion.

OPINION

¶1 Respondent, Jeremy Williams, appeals the September 12, 2024, order of the circuit court

of Crawford County that imposed additional terms and conditions upon his parenting time. On

appeal, Jeremy argues that the circuit court erred by imposing “additional terms and conditions

consistent with the previous allocation of parenting time” pursuant to section 607.5 of the Illinois

Marriage and Dissolution of Marriage Act (Dissolution Act) (750 ILCS 5/607.5 (West 2022)). For

the following reasons, we reverse and remand.

¶2 I. BACKGROUND

¶3 We limit our recitation to those facts relevant to our disposition of this appeal. We will

recite additional facts in the analysis section as needed to address the specific arguments of the

1 parties. Because the parties share a last name, we will refer to them by their first names throughout

this decision.

¶4 Abigail (Abby) and Jeremy married on August 1, 2013, in Panama City, Florida. Two

children were born to the parties: one in 2014 and another in 2018. Abby and Jeremy were both

raised in farming families in Crawford County, Illinois, and have been around farming practices

for most of their lives.

¶5 The parties separated on or about January 2, 2023. Until that time, the children resided with

the parties, and the parties shared in the care-taking functions for the minor children. On January

13, 2023, Abby filed a petition for dissolution of marriage.

¶6 On May 7, 2024, the parties entered into an agreed parenting plan allocating parental

responsibilities, significant decision-making, and parenting time. On May 15, 2024, the parties

entered into a marital settlement agreement. The agreed parenting plan and the marital settlement

agreement were adopted and incorporated into a judgment of dissolution of marriage, entered May

17, 2024.

¶7 Relevant to this appeal, the agreed parenting plan stated that, with regard to parenting time,

Abby shall have parenting time at all times not specifically allocated to Jeremy. Jeremy shall have

parenting time every other weekend from Friday after school to Monday when school commences,

and every Wednesday from after school until Thursday when school commences. Jeremy was also

given parenting time on the Tuesdays following Abby’s weekends. During summer break, the

parties agreed to parenting time on a “5-2-2-5” basis. Abby was given parenting time every

Monday from 8 a.m. to Wednesday at 8 a.m. Jeremy was given parenting time every Wednesday

from 8 a.m. to Friday at 8 a.m. with the parties alternating weekends.

¶8 Section 5(c) of the parenting plan specified:

2 “The parties acknowledge and agree that during planting and harvest seasons,

Father will be working additional and extended hours. During those periods, Mother shall

provide care for the children while Father is working. If Father works past 8:00 PM on a

school night, the children will stay at Mother’s residence for the night rather than change

residences at such a late hour. The overnights described herein shall not apply if there is

no school the next day.”

¶9 Section 5(g) of the parenting plan granted the parties the right to first refusal for childcare.

Section 5(g) stated:

“In the event that a parent is unable to be with the child(ren) for a period of eight

(8) hours or more, the other parent shall have the first option to provide care for the

child(ren) during the period of unavailability. The parties shall promptly advise each other

of the need for childcare as early in advance as possible and shall respond to each request

as promptly as possible. The parties further agree that if a parent is unavailable/working

past 8:00 PM and the other parent is providing care, the child(ren) shall remain with the

care-providing parent until the morning to avoid changing residences at a late hour.”

¶ 10 On July 10, 2024, Abby filed a petition to enforce parenting time and finding of contempt.

In her petition, Abby alleged that Jeremy abused his parenting time, because he failed to allow her

to provide care for the children while he worked during the 2024 planting season. Abby alleged

that Jeremy violated the agreed parenting plan by working at the farm during his parenting time

on 14 days from May 13, 2024, to June 19, 2024. Abby argued that due to the busy nature of the

planting and harvest season, Jeremy could not provide for the day-to-day care of the children

during his parenting time. Abby asked the court to find that Jeremy failed to comply with section

5(c) and (g) of the agreed parenting plan. She also requested that the court find him in indirect civil

3 contempt.

¶ 11 On July 30, 2024, the circuit court held a hearing on Abby’s petition to enforce parenting

time. The parties clarified their respective interpretations of the agreed parenting plan. Abby’s

position was that pursuant to section 5(c), during planting and harvesting season, if Jeremy was

working, the children were to be with Abby. Jeremy’s position was that section 5(c) was not

triggered until Jeremy worked “additional and extended hours.” At the hearing, Jeremy testified

that his farming operation, Williams Brothers, LLC, farmed approximately 1,625 acres of corn,

soybeans, wheat, milo, double-crop beans, and hay. He testified that the farming operation

employed five employees: Jeremy, his father, his uncle, his mother, and his aunt. Jeremy, his

father, and his uncle conducted the actual farming operation. Jeremy testified that ideally, they

begin planting the second week of April, but in 2024, they did not start planting until April 22. He

stated that in 2024, they finished planting on June 18.

¶ 12 Jeremy testified that throughout the year, the start and end of his workday varied. He stated

that he and his lawyer decided a typical workday ended at 5 p.m. and anything after that was

“additional and extended hours.” Jeremy stated that the “harvest and planting” language in section

5(c) of the agreed parenting plan “came about because of who was going to pick the children up

from school if I was busy planting or harvesting.” He opined that “the weekends are for me and

the children, and that we’re just addressing the additional and extended hours during the week.”

¶ 13 Jeremy further testified that since the execution of the agreed parenting plan, the children

had not been under the care and supervision of any third persons for more than eight hours during

his parenting time. Jeremy testified that he modified his farming schedule since the entry of the

agreed parenting plan so that he could be available to exercise his parenting time with the children.

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Stockton v. Oldenburg
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Bluebook (online)
2026 IL App (5th) 241260, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-marraige-of-williams-illappct-2026.