Issue: Under Illinois law, on appeal what is the standard of review applied to a district court’s award of child support?
Area of Law:
; Standard of Review; Child Support; Award; Abuse of Discretion
"The amount of a child support award is within the discretion of the trial court and will not be disturbed absent an abuse of discretion." In re Marriage of Scafuri, 203 Ill.App.3d 385, 391 (1990). "An abuse of discretion exists only where we can conclude that no reasonable person would take the view adopted by the trial court." In re Marriage of Heroy, 385 Ill.App.3d 640, 651 (2008).
"Calculating [child support] is a two-step process." In re Marriage of Mayfield, 2013 IL 114655, ¶ 16. "The trial court must determine the parties’ income, then apportion that income, setting an amount of child support for the noncustodial parent." Id. "Section 505(a)(3) of the Act governs the first step. It provides a definition of net income, which is the ‘total of all income from all sources, ‘ minus various deductions." Id. (quoting [statref]750 ILCS 5/505(a)(3) (West 2010) [/statref]).