In re Marriage of Graham

2021 IL App (3d) 200476, 194 N.E.3d 575, 457 Ill. Dec. 86
CourtAppellate Court of Illinois
DecidedDecember 10, 2021
Docket3-20-0476
StatusPublished
Cited by1 cases

This text of 2021 IL App (3d) 200476 (In re Marriage of Graham) 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 Marriage of Graham, 2021 IL App (3d) 200476, 194 N.E.3d 575, 457 Ill. Dec. 86 (Ill. Ct. App. 2021).

Opinion

2021 IL App (3d) 200476

Opinion filed December 10, 2021 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

In re MARRIAGE OF JANET C. ) Appeal from the Circuit Court GRAHAM, n/k/a Janet C. Michalek, ) of the 12th Judicial Circuit, ) Will County, Illinois, Petitioner-Appellant, ) ) Appeal No. 3-20-0476 and ) Circuit No. 08-D-1794 ) JAMES J. GRAHAM, ) Honorable ) David Garcia, Respondent-Appellee. ) Judge, Presiding. ___________________________________________________________________________

JUSTICE HOLDRIDGE delivered the judgment of the court, with opinion. Presiding Justice McDade and Justice Daugherity concurred in the judgment and opinion. ____________________________________________________________________________

OPINION

¶1 Janet C. Graham, n/k/a Janet C. Michalek, the petitioner, filed a petition for contribution

and reimbursement against James J. Graham, the respondent, for college expenses she paid on

behalf of the parties’ youngest daughter, which she argued was James’s responsibility to pay.

James filed a motion to dismiss the petition, which the circuit court granted. Janet appeals.

¶2 I. BACKGROUND

¶3 The parties were married for nearly 24 years and had three children. In October 2008, Janet

filed a petition for dissolution of marriage. The children were 23, 20, and 18 years old. In July 2010, the court entered an agreed dissolution judgment. The parties obligated themselves to pay

for their children’s college expenses if a child showed a propensity for educability and higher

learning. If so, the parties were to each pay one-third of the child’s college expenses and the other

one-third would be contributed by the child. College expenses included tuition, books, room and

board, health insurance, car insurance, medical expenses, and prior student loans. The payment of

college expenses was limited to not more than a consecutive four year course of study in college

or a training, vocational, or technical school immediately following graduation from high school.

At the time the dissolution judgment was entered, the parties’ youngest daughter, Olivia Graham,

was 20 years old (born July 1990) and attending college.

¶4 In November 2012, after a series of filings by the parties, the court modified the dissolution

judgment and stated that James “agrees to be responsible for all the college debt for all three of the

parties’ children, present and past and future expenses.” The order was signed by both parties next

to the word “agreed.” The order provided no further changes to the dissolution judgment as it

related to college expenses but addressed other issues relating to maintenance.

¶5 In June 2020, Janet filed a petition for contribution and reimbursement of college expenses

and debts against James. She alleged that she incurred $1693 in debt for Olivia’s college expenses,

who was still working toward her four-year degree, and requested reimbursement. It was Janet’s

position that the 2012 modification made James liable for all college expenses (past, future, and

present) without limitation, such as the length of time allowed to pursue a four-year degree.

¶6 James filed a motion to dismiss Janet’s petition pursuant to section 2-619 of the Code of

Civil Procedure (Code) (735 ILCS 5/2-619 (West 2020)). First, he argued that the petition was not

commenced within the time limited by law. Specifically, the 2016 amendment to section 513(a) of

the Illinois Marriage and Dissolution of Marriage Act (Act) allowed parties to extend the time for

2 a petition to be brought for post high school expenses past a child’s 23rd birthday. 750 ILCS

5/513(a) (West 2016); see Pub. Act 99-90 (eff. Jan. 1, 2016). However, that section also required

that the expenses be incurred no later than the child’s 23rd birthday, except for good cause shown,

but in no event later than the child’s 25th birthday. James stated that the petition for reimbursement

was filed shortly before Olivia’s 30th birthday for expenses that occurred after her 23rd birthday

and that no good cause was alleged to extend the expenses beyond her 23rd birthday.

¶7 Second, James argued that the payment of college expenses was limited to not more than

four years of study immediately following graduation of high school and that the expenses for

which reimbursement was sought were incurred long after the expiration of the four consecutive

years following Olivia’s high school graduation.

¶8 Third, James contended that Olivia did not demonstrate a propensity for educability and

higher learning. He noted that she attended college part-time on an off-and-on basis at four

colleges. James stated that Olivia now wished to transfer to another college but it would take at

least two more years for her to obtain a bachelor’s degree if she attended full-time and achieved

passing grades. He noted that she did not have a cumulative “C” average, failed numerous classes,

and was not admitted into a teaching program due to having a less than 2.0 GPA. Further, many

of her course credits would not transfer to subsequent schools due to her low grades.

¶9 James provided that he paid all college expenses incurred within four consecutive years of

her high school graduation date and his obligation to pay college expenses terminated. Although

he was not legally required to do so, he continued to pay Olivia’s college expenses until she

obtained her associate’s degree, long after her 23rd birthday. James also stated that Olivia attended

Rockford University part-time in the spring of 2020 and owed a balance of $1693. However, she

received a reimbursement from Rockford University in the amount of $2290 due to Covid-19 and

3 used the refund for a down payment on a home. James attached his affidavit to his motion in

support of these facts. Janet responded to James’s motion and attached Olivia’s affidavit providing

that Olivia attended college after the 2012 modification and incurred $25,823 in loans to pay for

her college expenses.

¶ 10 In October 2020, the matter proceeded to hearing. The court clarified Janet’s position: “So

if I take your position, [Olivia] could be 100 and [James] could be 120 and *** he’d still have to

pay.” To which Janet’s counsel responded, “the man agreed to pay for the parties’ college debt,

past, present, and future expenses. And there’s *** no limit on that.” The court disagreed and

dismissed Janet’s petition with prejudice. The court found that the 2012 modification only changed

who paid for the college expenses. Janet appeals.

¶ 11 II. ANALYSIS

¶ 12 Janet argues that the court erred as a matter of law when it granted James’s motion to

dismiss because the 2012 modification required that James pay all college expenses for their

children without restriction. Specifically, she claims that the 2012 modification providing that

James be solely responsible for the children’s college expenses superseded all conditions in the

2010 dissolution judgment. James argues that the expenses for which Janet seeks reimbursement

were not incurred within the applicable time frame, he paid all expenses for which he was liable,

and the reimbursement sought failed to meet the condition precedent that the child demonstrate a

propensity for educability and higher learning that was set forth in the 2010 dissolution judgment.

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2021 IL App (3d) 200476, 194 N.E.3d 575, 457 Ill. Dec. 86, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-marriage-of-graham-illappct-2021.