The 2016 law changed dramatically Illinois law regarding removal of children. Even the title has changed, with removal now being called relocation. But we can see that the 2016 relocation statute generally codifies what had been Illinois while continuing to be restrictive in terms of whether or not relocation should be allowed. With the 25 and 50-mile rules as part of our statutory scheme, Illinois has one of the most restrictive laws in the States. This article has not been comprehensively updated since 2016 because of the author’s concentration on updating his spreadsheet and the book Chapter on Relocation. This includes ongoing work with a breakdown of historical and current case- law based upon the 10-plus factors. One should understand by reviewing the statute and current case law that no longer is the focus on indirect benefits. Rather the focus of a lawyer in assisting a client with a case seeking relocation or opposing relocation is that great deference is given to the trial court’s decision, going back to the language of the seminal In re Marriage of Eckert Illinois Supreme Court decision.
It is rare that we have multiple Supreme Court decisions on a somewhat narrow area of law. For removal/relocation cases we now have four! See Gitlin on Divorce for a current and detailed discussion.