In re Marriage of S.D., 2012 IL App (1st) 101876

N/A

OUTCOME:

In postjudgment proceedings arising from the dissolution of the parties’ marriage, the trial court properly considered the wife’s petition as a petition to modify rather than review support, the trial ... court did not err in applying the substantial change in circumstances standard to her petition, respondent husband was properly granted a retroactive decrease in his maintenance obligation, and petitioner was properly found liable for respondent’s attorney fees pursuant to the penalty clause in the parties’ settlement agreement.