In re Marriage of Hamm

2022 IL App (2d) 220010-U
CourtAppellate Court of Illinois
DecidedAugust 29, 2022
Docket2-22-0010
StatusUnpublished

This text of 2022 IL App (2d) 220010-U (In re Marriage of Hamm) 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 Hamm, 2022 IL App (2d) 220010-U (Ill. Ct. App. 2022).

Opinion

2022 IL App (2d) 220010-U No. 2-22-0010 Order filed August 29, 2022

NOTICE: This order was filed under Supreme Court Rule 23(b) and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

In re MARRIAGE OF ) Appeal from the Circuit Court JARED W. HAMM, ) of McHenry County. ) Petitioner-Appellee, ) ) and ) No. 21-DV-644 ) CHELSEY K. LESNIAK, ) Honorable ) Justin M. Hansen, Respondent-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE BRENNAN delivered the judgment of the court. Justices Hudson and Birkett concurred in the judgment.

ORDER

¶1 Held: The trial court erred in its award of educational expenses. Affirmed in part, vacated in part, and remanded.

¶2 Following the parties’ dissolution-of-marriage judgment and after one of their children

turned 18, petitioner, Jared W. Hamm, filed a petition for modification of child support;

respondent, Chelsey K. Lesniak, subsequently filed a petition for educational expenses. The trial

court granted both petitions, ordering, in relevant part, that the parties each pay half of the child’s

tuition at a private university after subtracting subsidized loans, grants, and scholarships from the 2022 IL App (2d) 220010-U

tuition amount. Chelsey appealed from the order awarding educational expenses. For the following

reasons, we affirm in part, vacate in part, and remand the cause for further proceedings.

¶3 I. BACKGROUND

¶4 The parties were married in 2002 and have two children (born in 2002 and 2003). A

dissolution-of-marriage judgment was entered on March 22, 2011, and incorporated the parties’

marital settlement agreement (MSA). In relevant part, the MSA provided:

“COLLEGE. Husband and Wife shall provide each child with a college education

if the said child attends an accredited college, university or trade school as a full-time

student, even though he/she has reached the age of majority, if the child is educable and

each party shall pay in accordance with the party’s financial ability to provide said

education and considering the financial resources of the child. The child must attend the

said college, university or trade school as a full-time student within one (1) year of his or

her graduation from high school, and must complete the said schooling in a normal time

recommended by the said school. The child and the parties shall each communicate his or

her preference for choice of school (This is not a condition of liability).”

¶5 On September 2, 2021, Jared filed a petition for modification of child support to terminate

his child support obligation for the child who had turned 18. On September 14, 2021, Chelsey filed

a petition for educational expenses pursuant to section 513 of the Illinois Marriage and Dissolution

of Marriage Act (Act) (750 ILCS 5/513 (West 2020)) for the parties’ emancipated child who was

attending college at Lindenwood University (Lindenwood) in Missouri. The exhibits attached to

the petition included Lindenwood billing ledgers and reflected that the tuition at Lindenwood for

the 2020/2021 academic year was $18,000 ($9000 per semester) but the child received a total of

$7000 in academic grants ($3500 per semester); the tuition at Lindenwood for the fall semester

-2- 2022 IL App (2d) 220010-U

2021 was $9270 but the child received a $3500 academic grant for the semester; and the tuition at

the University of Illinois at Urbana-Champaign (UIUC) for the 2021/2022 academic year was

$12,254. 1 Both parties represented themselves throughout the trial court proceedings.

¶6 A. Trial Court’s Ruling

¶7 On October 25, 2021, following a hearing at which both parties testified regarding their

respective contributions to the child’s educational expenses, the trial court granted both petitions.

In its oral findings, the trial court reasoned that section 513 of the Act provides that educational

expenses shall not exceed that amount paid by a student at UIUC for the same academic year. “So

to the extent that [the child] is going somewhere where the tuition and the room and board is higher

than what U of I would be, I’m not authorized to order either party to pay that amount.”

Accordingly, the trial court ordered the parties to pay the tuition per semester as follows:

“Starting at $12,254, which is the amount of tuition based upon the evidence at

Illinois for one semester, first from that number will be subtracted any subsidized loans

that [the child] is able to qualify for. From the [$]12,254, minus the amount of subsidized

loans that [the child] can qualify for, the parties will also subtract any grants, scholarships

or other non-loan financial aid that she qualifies for. So I’m making numbers up, but if in

total she has $3,000 in subsidized loans and a grant from the school, the remaining tuition

would be [$]9,254. The parties will divide that equally between the two of them, 50 percent

and 50 percent.”

1 The billing ledgers also reflected receipt of subsidized and unsubsidized student loans and

a Parent Plus loan.

-3- 2022 IL App (2d) 220010-U

¶8 The trial court recognized that its order “creates a deficit right from the get-go because

right from the get-go, her tuition is several thousand dollars more per semester” but stated that it

did not have “the authority to order a remedy to that today.” Namely, “I can’t order payments of

tuition above and beyond what Illinois is, so the remaining five or six thousand dollars that would

be due is basically not addressed by this court order.” The trial court further detailed the amount

that each party was required to pay for room, board, and fees; this portion of the order is not at

issue in this appeal.

¶9 After the trial court set forth its findings, Chelsey sought clarification as to the amount of

tuition that each party was required to pay. The following colloquy ensued:

“CHELSEY: “So we’re taking [the child’s] total tuition at Lindenwood, subtracting

out subsidized loans, grants and scholarships and then splitting the rest at 50/50 as long as

it doesn’t exceed the University of Illinois’s cost. Or did I say that backwards?

THE COURT: We are on the same page, but I’m using the tuition number from the

University of Illinois—

CHELSEY: Not her tuition, though.

THE COURT: Right. So [$]12,254, which is the U of I number, minus subsidized

loans, grants and scholarships. The remainder of that figure will be split 50/50 by the

parties. And the court recognizes that’s going to leave a balance that you folks either need

to figure out or she needs to figure out.”

¶ 10 The trial court’s October 25, 2021, written order on the petition for educational expenses

provided in relevant part:

“Tuition. The tuition at Lindenwood University exceeds that of U of I at Urbana-

Champaign (“UIUC”). Therefore, tuition payments under this order are capped at $12,254

-4- 2022 IL App (2d) 220010-U

per semester, the amount of tuition at UIUC according to the evidence presented at hearing.

To determine each party’s responsibility, the amount of any subsidized loans, grants, and

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2022 IL App (2d) 220010-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-marriage-of-hamm-illappct-2022.