Background
S.G. and E.G. divorced following a 2019 parental allocation judgment that awarded them joint decision-making authority and equal parenting time with their then-two-year-old son, A.G. The parties co-parented without court intervention until February 2023, when E.G. filed motions to enforce and modify the allocation judgment regarding school placement and vaccinations. The disputes escalated, involving disagreements over medical care (including recommended ear tube surgery and tonsil/adenoid removal), dental treatment, extracurricular activities, and numerous other parenting decisions.
During the dispute resolution process, S.G. engaged in extensive harassment of court-appointed professionals and healthcare providers, posting negative online reviews, sending thousands of emails demanding changes to a guardian ad litem’s recommendations, and causing two specialists to discharge A.G. as a patient due to his disruptive conduct. S.G. also recorded a conversation with A.G. in which he led the child to discuss disliking baseball and attempted to demonstrate that he understood A.G.’s wishes better than E.G. The trial court found this recorded conversation particularly troubling, describing it as containing coaching designed to undermine E.G.’s parenting authority.
In August 2025, following a five-day trial, the trial court substantially modified the 2019 allocation judgment. The court stripped S.G. of decision-making authority over education, extracurricular activities, and medical matters, awarding sole decision-making to E.G. in these areas. The court also temporarily restricted S.G.’s parenting time to two weeks of supervised visitation with conditions requiring him to speak positively about E.G. and attend a parenting class.
The Court’s Holding
The appellate court affirmed the trial court’s modifications on two grounds. First, the court found a substantial change in circumstances since the 2019 judgment, pointing to A.G.’s increased age (from two to eight years old), his enrollment in school, and critically, the extensive litigation between the parents regarding his education, medical care, and extracurricular activities. The court rejected S.G.’s argument that these factors alone did not constitute a substantial change, noting that the totality of circumstances—including the parties’ complete inability to cooperate in joint decision-making—supported the trial court’s finding.
Second, the appellate court upheld the modification as in A.G.’s best interest. The court found sufficient evidence that S.G.’s conduct undermined E.G.’s parenting authority, that he inappropriately coached A.G. against his mother, and that his pattern of harassing healthcare providers and court-appointed professionals interfered with A.G.’s medical and dental care. The court emphasized that S.G. caused delays in necessary treatment, cancelled court-ordered appointments, and engaged in conduct causing providers to refuse to treat A.G. The appellate court noted it could not reweigh evidence or reassess credibility determinations made by the trial judge, who was in the superior position to evaluate witness testimony.
Regarding the temporary supervised parenting time restriction, the appellate court held that the trial court did not abuse its discretion. The court found that S.G.’s conduct—particularly the recorded conversation in which he coached A.G. and the broader pattern of undermining E.G.’s authority—constituted serious endangerment to A.G.’s mental health and his relationship with his mother. The two-week supervised visitation with conditions was a reasonable, narrowly tailored restriction designed to prevent further mental health effects while allowing S.G. time to complete a parenting class and modify his behavior.
Key Takeaways
- Courts will find a substantial change in circumstances justifying modification of custody arrangements when parties have become unable to cooperate in joint decision-making and have engaged in extensive litigation over the child’s education, medical care, and activities.
- A parent’s pattern of harassing healthcare providers, specialists, court-appointed guardians ad litem, and the other parent can constitute serious endangerment to a child’s mental health, particularly when combined with evidence of inappropriate coaching or alienation of the child from the other parent.
- A parent’s interference with necessary medical and dental treatment—through excessive questioning, cancellation of appointments, or conduct causing providers to refuse care—can justify removal of medical decision-making authority even absent physical harm to the child.
- Recorded conversations between a parent and child in which the parent leads the child to criticize the other parent or the other parent’s choices constitute evidence of inappropriate coaching and mental health endangerment warranting restrictions on parenting time.
Why It Matters
This decision provides significant guidance on when courts will abandon joint custody arrangements due to parental conduct short of physical abuse or violence. The case illustrates that repeated harassment of healthcare providers, judges’ court-appointed representatives, and the other parent—particularly when coupled with evidence of child coaching or alienation—can rise to the level of serious endangerment justifying substantial restrictions on parenting time and decision-making authority. The appellate court’s affirmance emphasizes that trial courts have broad discretion to protect children from the mental health effects of parental conflict and alienation, and that appellate courts will defer substantially to trial judges’ credibility determinations in these highly fact-intensive cases.
For practicing attorneys, this case demonstrates that behavior toward third parties (providers, court officials) can be highly probative in custody disputes. The court gave significant weight to the trial judge’s in-courtroom observations of S.G.’s demeanor and his testimony, as well as the recorded conversation between S.G. and A.G., underscoring the importance of preserving evidence of parental conduct in custody modification litigation. The decision also reflects Illinois courts’ willingness to modify even recently-established joint custody arrangements when circumstances demonstrate the parents cannot cooperate and one parent’s conduct is harming the child’s relationship with the other parent.