College Expenses

by Wes Cowell, updated 13 August 2017 -- suggest a correction

 

Once child support stops, "college expense contribution" can start.  Don't delay — start your case when filling out college applications.  If your agreement says you'll both contribute to college expenses, you can get retroactive relief.  If your agreement isn't clear, however, you can win contribution for future  expenses,  but  probably  cannot  win  retroactive  reimbursement  for  past  expenses. Need advice?  Callleave your info, or schedulescheduleschedule a consult.

 

Child support in Illinois stops when a kid turns 18 (or upon H.S. graduation, whichever is later, and it stops at 19 even if the child is still in H.S.).  All the support issues that you've previously addressed under the "child support" law must be shifted over into the "college expenses" law.  The college expense law applies to "non-minor children;" i.e., those over 18.

 

The Basics:  Illinois law (750 ILCS 5/513) gives judges the power to allocate college expenses -- even expenses incurred during school breaks (750 ILCS 5/513(d)(4)) -- for children whose parents are divorced.  The law defines "educational expenses" as including (but not being limited to) tuition and fees, housing (whether on- or off-campus), medical insurance and expenses, dental expenses, books and other supplies.

 

Living At Home While Going to School:  If the student lives with a parent while attending school, the court is to consider the child's living expenses and allocate between the parents and child "an amount that pays for the reasonable cost of the child's food, utilities, and transportation."  750 ILCS 5/513(d)(4)(B).

 

The Financial Caps:   The law ties a parent's maximum contribution to the cost of tuition, fees, room-and-board (double occupancy, standard meal plan in a residence hall) at the University of Illinois, Champaign / Urbana.

 

Other Restrictions:  The child must maintain at least a "C" grade average.  Payments are to end -- no matter what -- upon a child's 23rd birthday (or 25th for good cause, like, a delayed start due to military service).  750 ILCS 5/513(d).  I'm reminded of the lament of Senator John Blutarsky:  "Seven years of college down the drain . . . might as well join the Peace Corps."

 

Unlike child support, the parents' contribution to college expenses is not dictated by a formula or guideline spelled out in the law – it is left to the discretion of the judge.  In re: Marriage of Zukausky, 244 Ill.App.3d 614, 184 Ill.Dec. 367, 613 N.E.2d.

 

Beyond the statutory limitations, courts also employ common sense.  A parent should not be ordered to pay more for college than he or she can afford.  In re: Support of Pearson, 111 Ill.2d 545, 96 Ill.Dec. 69, 490 N.E.2d 1274 (1986); In re: Marriage of Thurmond, 306 Ill.App.3d 828, 240 Ill.Dec.127, 715 N.E.2d 814 (2d Dist., 1999); In re: Marriage of Fahy, 208 Ill.App.3d 677, 153 Ill.Dec. 594, 567 N.E.2d 552 (1st., Dist., 1991).

 

Never-Married Parents:  Parents of children born out of wedlock may also apply to the court for assistance with college expenses from the other parent.  The Illinois Parentage Act (of 2015) states

Sec. 801. Child support orders. 
    (a) Notwithstanding any other law to the contrary, pending the outcome of a judicial determination of parentage, the court shall issue an order for child support upon motion by a party and a showing of clear and convincing evidence of parentage. In determining the amount of the child support award, the court shall use the guidelines and standards set forth in Sections 505 and 505.2 of the Illinois Marriage and Dissolution of Marriage Act.

Notice that it doesn't say anything about college expenses.  The college-expense language wasn't included in the earliest versions of the parentage law and the law-makers didn't deign to include in this latest version, either.  That's because the Illinois Appellate Court case of Rawles v. Hartman, 172 Ill.App.3d 931, 123 IllDec.217, 527 N.E.2d 680 (2d Dist., 1988) made it unnecessary.  

 

Glenda Rawles and Morton Hartman, without benefit of marriage, had a baby girl, Debra in May, 1969.  They got along pretty well for 17 years and 10 months . . . so close.  In March, 1987, Glenda went to court to ask for child support and a deal was worked out whereby Morton agreed to pay support through July, 1987 (that's right, he agreed to continue paying for three months past Debra's majority; probably to pay down an arrearage).  That fall, Debra started college and in October, Glenda went back to court to ask that Morton help with the college expenses.  Morton objected.  He pointed out that the parentage law didn't say anything about college expenses -- that obligation was only for folks who were dumb enough to marry then divorced.  The trial court sided with Morton but, on appeal, the appellate judges said "what's-good-for-kids-of-divorce-is-good-for-kids-of-the-never-married:"

When read together, the two acts establish that the court has broad discretion to determine any award of child support, including support for educational expenses beyond the age of majority despite the absence of a specific provision for the education of non-minor, illegitimate children. Where two acts in pari materia are construed together and one of them contains provisions omitted from the other, the omitted provision will be applied in a proceeding under the act not containing such provisions, where not inconsistent with the purpose of the act. In re Marriage of Pick (1983), 119 Ill.App.3d 1061, 1067, 75 Ill.Dec. 865, 458 N.E.2d 33.

        . . . the purposes of the Parentage Act are to provide for the support of the child and to prevent the child from becoming a public charge. We conclude that it is consistent with those purposes for a court, in a parentage proceeding, to apply section 513 of the Dissolution Act so as to provide for the education of a non-minor, illegitimate child as equity requires. This will effectuate the legislative intent to treat all children equally in matters of support. . . .

. . . 

 

        The State may not invidiously discriminate against illegitimate children by denying them substantial benefits accorded legitimate children; once the State posits a judicially enforceable right on behalf of children to needed support from their natural fathers, there is no constitutionally sufficient justification for denying such an essential right to a child simply because its natural father has not married his or her mother. For a State to do so is illogical and unjust. Gomez v. Perez (1973), 409 U.S. 535, 539, 93 S.Ct. 872, 875, 35 L.Ed.2d 56, 60.

        Consistent with Gomez, our construction of the Illinois statutory scheme effectuates the legislature's intent to provide equal treatment to legitimate and illegitimate children in matters of support.

Rawles v. Hartman, 172 Ill.App.3d 931, 123 IllDec.217, 527 N.E.2d 680 (2d Dist., 1988)

Retroactive Relief -- No for "Establishing" Support | Yes for "Enforcing" a Contract :  If you want the other parent to help with college expenses, first, look at your Judgment / Marital Settlement Agreement.  If "college expenses" are adequately addressed, you have a contract  between the parents that may be enforced, even retroactively.  Illinois' statute of limitations to enforce a written contract is ten years.

 

If the Judgment or MSA is silent or "reserves" college expenses, then you DON'T have a contract and you need to first "establish" support.  That means you're filing a new claim sounding in child support, and there can be NO RETROACTIVE RELIEF.  Since 2017, the law has said:

(k) The establishment of an obligation to pay under this Section is retroactive only to the date of filing a petition. The right to enforce a prior obligation to pay may be enforced either before or after the obligation is incurred.

750 ILCS 5/513(k)

To read this law like a lawyer or a judge, focus on the word "establishment."  If you've not yet "established" college expense contributions, then you can't get retroactive help for costs already incurred.  You can only hope to get help for the bills yet to come.  If, however, your Judgment or MSA has already "established" the parents' responsibilities to contribute, then you're not "establishing" anything . . . you're "enforcing" obligations that already exist.

 

This law merely codifies what the caselaw said before it, so I'm including all the meaty cases on this topic even though they predate the (redundant) statute.

Silence or Express Reservation = "Modification" = No Retroactive Application:  One pitfall to avoid in your MSA is failing to address or "reserve" college expenses in the MSA.  Many MSAs don't even mention college expenses.  It's also common for judgments to "reserve" the issue as the children are simply too young at the time of the divorce for the parents to know whether college will be appropriate.  In such situations, courts will often order that the issue of college expenses is "reserved."  It simply means "we'll wait and see what we need to do when we need to do it."  That's what happened when Kevin and Janet Petersen divorced in August, 1999.  Petersen v. Petersen, 2011 IL 110984 (Ill., 2011).  Their judgment said "The Court expressly reserves the issue of each party's obligation to contribute to the college or other education expenses of the parties' children pursuant to Section 513 of the Illinois Marriage and Marriage Dissolution Act." (emphasis added).

 

Eight years later, in May, 2007, Janet went back to court to get the college expenses squared away.  They had three boys.  The eldest attended college between 2002 and 2006 and was all done by the time Janet went back to court.  The middle son was finishing the last few weeks of his second year of college.  The youngest son was a few days away from his high school graduation.

 

Kevin argued that because the issue of college contributions had been reserved, he previously had had no obligation at all and Janet was really trying to modify their judgment; and that meant that she could not get retroactive relief.  Janet argued that because the college contribution issue had been reserved, it had never been ruled on and she could go back in time and get reimbursement for the costs of the eldest son's four years of college and the middle son's first two years -- all of which had occurred PRIOR to Janet's filing.

 

The Illinois Supreme Court resolved the controversy saying:

 

Illinois decisional law has since 1986 consistently regarded the actions taken pursuant to reservations clauses to be modifications under section 510 subject to the prohibition of retroactive support.

Petersen v. Petersen, 2011 IL 110984 (Ill., 2011).

 

So, according to the Supremes:

  1. Janet was trying to modify the Judgment regarding college expenses;

  2. college expenses are a form of child support.

  3. there can be no retroactive modifications of child support;

therefore, Janet lost.

 

If the MSA Defines College Contributions = Retroactive Enforcement Applies :  The law says no retroactive ESTABLISHMENT for college expense claims. But if the obligation existed from the time of the Judgment/ MSA, then you're talking about ENFORCEMENT.

 

After Petersen (2011), other cases more clearly defined things:

 

In re:  Marriage of Spircoff, 2011 IL App (1st) 103189, 355 Ill.Dec. 491, 959 N.E.2d 1224.  The MSA provided that "[e]ach of the parties shall contribute to the trade school or college and professional school education expenses of their child in accordance with section 513."  The child ended up having to sue Mom and Dad to get the college funding.  NOTE:  Illinois law was changed 1/1/2016 and kids can no longer assert thrid-party-beneficiary standing to sue for themselves.  Mom and Dad argued that Petersen prohibited retroactive applicaiton of the MSA's requirement.  The trial court concluded that the language in the MSA amounted to a "reservation" and the child appealed.  The appellate court ruled in the child's favor holding that "the obligation of the parties for educational expenses was clearly and affirmatively stated and was not expressly reserved, even though the actual allocation of the expenses was not made when the judgment for dissolution was entered."  In re:  Marriage of Spircoff, 2011 IL App (1st) 103189, 355 Ill.Dec. 491, 959 N.E.2d 1224

 

In re:  Marriage of Koenig, 2012 (IL App (2d) 110503, 360 Illl.Dec.652, 969 N.E.2d 462 (2d Dist., 2012): The parties divorced in 1993 and their MSA said "[t]he Husband and Wife shall pay for university, college, or post-graduate school education for [their daughter] herein based on the respective financial abilities and resources at said time."  Seventeen years later, Joyce (the former wife) filed for college expense contributions from her former husband (James) for their daughter's college (U.C. Santa Barbara) and law school (Pepperdine) expenses -- more than $250,000, altogether.  Joyce's problem, however, was that she had waited until their daughter had finished law school  -- she was seeking entirely retroactive relief.  James held up Petersen and said "you can't get retroactive relief; you waited too long."  The trial court agreed with James, granted summary judgment, and Joyce appealed.  The appellate court said:

 

Here, unlike in Petersen, the parties' settlement agreement . . . contained neither a reservation clause on the issue of college and post-graduate expenses nor any reference to section 513; rather, it affirmatively assigned responsibility to both parties for Tiffany's college and post-graduate expenses, and therefore any order entered pursuant to Joyce's petition wold not 'adjust, change, or alter" this obligation . . . .  Joyce is not barred from retroactively seeking . . . [contribution to] Tiffany's college and post-graduate expenses.

In re:  Marriage of Koenig, 2012 (IL App (2d) 110503, para. 17, 360 Illl.Dec.652, 969 N.E.2d 462 (2d Dist., 2012)

 

In re:  Marriage of Donnelly, 2015 IL App. (1st) 142619:  Joe and Rene Donelly divorced in 1996 with four kids.  The MSA said "Pursuant to Section 513 . . . the parties covenant and agree that they shall pay for a trade school, vocational school, college or university education for the children of the parties . . . ."  In 2013, Renee went back to court complaining that she had paid more than $100,000 on the kids' college expenses since 1998 -- that's 15 years of college expenses.  She sought retroactive applicaiton of the language in the MSA.  Joe held up Petersen as his shield.  The trial court denied Joe's Motion to Dismiss, but the court alowed Joe to take the question to the appellate court.  The appellate court said:

 

The language of the agreement . . . expressly obligated the parties to pay for a trade school, vocational school, college or university education for the children of the parties.  The language of the agreement is thus similarly distinguishable from the express judicial reservation of the issue of the parties' obligaiton presented in Petersen.

. . . 

In short, the parties entered into a settlment agreement obligating them to pay for a trade school, vocational school, college or university education for their children, with the extent of the parties' obligation to be based upon their then respective financial conditions.  Under the circumstances, the holding in Petersen [ ]  does not preclude the circuit court from ordering a parent to reimburse the other parent for college expenses allegedly paid prior to the date the petition is filed, even where the parties' judgment for dissolution does not order a specific dollar amount or percentage to be paid but leaves the the amound to be determined at a later date.v

In re:  Marriage of Donnelly, 2015 IL App. (1st) 142619.  

 

So, there you have it:  if the MSA is silent or expressly reserves the issue, there can be no retroactive recovery of college expenses because college expenses are a form of child support and there can be no retroactive modification of child support.  If the MSA mentions the obligation to contribute to college -- even if it doesn't define who has to pay how much -- that's a contract and contracts can be enforced retroactively.  

 

As an aside, I'm not sure how Joyce Donnelly was able to go back so far in time.  She complained about 15 years of educational expenses . . . but the statute of limitations on written contracts is only ten years.

Pre-Decree Expenses?  Use Rights of Married Persons Act for "Reimbursement":  A child's "educational expenses" are the responsibility of both parents under Illinois' Rights of Married Persons Act (750 ILCS 65/15(a)(1)).  That law speaks in terms of "children," not "minor children."  So, if you're ever in a jam, you can try to use that law to argue that the family law court has the authority to order the reimbursement of fees and expenses paid prior to the filing of the relevant Petition.  That's what happened in In re: Marriage of Bennett, 306, Ill.App.3d 246, 713N.E.2 d 1278 (2d Dist., 1999).

This is a pre-decree / Judgment for Dissolution case -- not a post-decretal case.  Edgar and Beatrice Bennet were divorcing. Beatrice had been named the trustee of about $40,000 for benefit of their daughter, Karen.  Karen attended Berklee College of Music, in Boston.  Beatrice refused to release any of the trust money, so Edgar had to write checks to cover Karen's tuition and expenses.  After three years of this, Edgar finally complained in the divorce court that, not only wasn't Beatrice helping, she wasn't even allowing Karen to tap the trust money.  Edgar had paid out some $75,000 and he wanted some retroactive relief.  Edgar could have just called this marital debt and probably gotten away with it that way, but instead he argued for "reimbursement."

 

Beatrice held up the "no-retroactive-relief-beyond-the-date-of-filing" defense.  The court made short shrift of Beatrice's argument:

 

Beatrice argues that, since a trial court has no authority to retroactively modify a child support order (citation omitted) there is no authority for a court to impose a support reimbursement order retroactively for funds expended before the case was filed.  However, she cites no case law or statute prohibiting the court from ordering reimbursement  for the educational expenses paid prior to the filing of a petition for dissolution.  The appellate court has considered reimbursement for the educational costs expended after an order of dissolution, and the concept was not rejected, See, Singer v. Singer, 70 Ill.App.3d 472, 27 Ill.Dec.88, 388 N.E.2d 1051 )1979) . . . Furthermore, a child's educational expenses are chargeable to both parents under Section 15(a)(1) of the Rights of Married Persons Act. (the Expense Statute).  See, 750 ILCS 65/15(a)(1).  Under the Expense Statute, creditors may sue parents jointly or separately for family and education expenses.  Thus, Beatrice could have been held liable for all or any portion of Karen's expenses before or after the petition for dissolution was filed.  See, Proctor Hospital v. Taylor, 279 Ill.App.3d 624, 626-27, 216 Ill.Dec. 614, 665 N.E.2d 872 (3d Dist., 1996).  We decline to hold that a trial court abuses its discretion in granting reimbursement for the educational expenses paid before the filing of a petition for dissolution and find no error here. 

In re: Marriage of Bennett, 306, Ill.App.3d 246, 713N.E.2 d 1278 (2d Dist., 1999).

 

Always Modifiable:   College contributions are a form of child support.  In re:  Marriage of Dieter, 271 Ill.App.3d 181, 190 207 Ill.Dec. 848 648 N.E.2d 304 (1995).

 

"Illinois courts have consistently held that section 513 expenses (i.e. college expense contributions) are a form of child support to be read in conjunction with section 505. See, In re Marriage of Sreenan, In re Marriage of Waller, 339 Ill. App. 3d 743 (2003). See also In re Marriage of Truhlar, 404 Ill. App. 3d 176 (2010)"

Petersen v. Petersen, 2011 IL 110984 (Ill., 2011).

That means college contribution obligations are always modifiable to serve the best interests of the child.  In re:  Marriage of Loffredi, 232 Ill.App.3d 709, 173 Ill.Dec. 933, 597 N.E.2d 907 (1992).

 

Most Judgments and MSAs speak only vaguely of the "contribution to college expenses" requirement.  It is rare to see (and bad form to include) a specific formula (like, "Mom will pay 10%, the child will pay 30% and Dad will pay 60%).  All judges and most parents prefer to take a wait-and-see approach to college expenses.  After all, what if the child doesn't turn out to be college material?  Spelling out the obligations in advance can lead to disaster.  See,  In re:  Marriage of Mulry, 314 Ill. App. 3d 756, 247 ll. Dec., 612, 732 N.E.2d 667 (4th Dist., 2000).  Provisions in MSAs allocating costs or percentages of college, are always modifiable because Section 513 contributions are in the nature of child support – and child support is always modifiable (but not retroactively) to serve the best interests of the children:

 

Given the statute's express language and its history, it is not surprising that Illinois courts have consistently held that section 513 expenses are a form of child support to be read in conjunction with section 505. See In re Marriage of Sreenan, 81 Ill. App. 3d 1025 (1980); In re Marriage of Coram, 86 Ill. App. 3d 845 (1980); In re Marriage of Waller, 339 Ill. App. 3d 743 (2003). See also In re Marriage of Truhlar, 404 Ill. App. 3d 176 (2010). "Support" as that term is used in section 510(a) means amounts required to be paid under a judgment, decree, or order issued by a court of competent jurisdiction, for the support and maintenance of a child, including a child who as attained the age of majority under section 513. In fact, section 510 specifically includes language which references both section 505 and section 513. We therefore find no merit in Janet's argument that college expenses do not constitute "child support" and that, as a consequence, section 510 is inapplicable.

Petersen v. Petersen, 2011 IL 110984 (Ill., 2011)

 

The Adult Child Chooses the School:  One primary concern of divorcing parents (at the time of the divorce) is that they have a voice in the selection of the school and curriculum for their child.  Why, after all, should a divorced parent be forced to pay for an education that he or she could refuse to pay for if still married?  Forget about it.  The law has no requirement that a parent be consulted about the college the child will attend and such a requirement may not be inferred.  In re:  Marriage of Fritch, 224 Ill.App.3d 29, 586 N.E.2d 427, 166 Ill.Dec. 469 (1st Dist., 1991).

 

Who Pays How Much?:  When it comes time to actually talk about who-pays-how-much, the court must consider "all relevant factors that appear reasonable and necessary, including:

 

  1. the present and future financial resources of both parties to meet their needs, including, but not limited to savings for retirement,

  2. the standard of living the child would have enjoyed had the marriage not been dissolved,

  3. the financial resources of the child, and

  4. the child's academic performance."

 

That language about "the financial resources of both parties" is significant.  We're not talking about "income," as we do with "child support."  For college expenses, we're looking at "financial resources," that means the court may consider the marital resources if a parent has remarried.  That means the court may even consider the assets of a second spouse and the expenses of a second family.  Imangine that:  you marry and your new spouse has kids -- your own income or assets might be tapped by the court to defray the educational expenses of your new spouse's kids from a prior marriage.  Ouch!  In re: Marriage of Street, 325 Ill.App.3d 108 (2001), In re: Marriage of Drysch, 314 Ill.App.3d 640 (2d Dist., 2000). In re: Marriage of Sreenan, 81 Ill.App.3d 1025.  The court may also consider the payment or receipt of maintenance (alimony) in making its determination.  In re: Marriage of Albiani, 159 Ill.App.3d 519, Ill.Dec. 126, 512 N.E.2d 30 (1st DIst., )

 

Types of Schools Covered:  The law covers pretty much any kind of post-high school education, referring to "college education or vocational or professional or other training after graduation from high school."  That has been held to include trade schools.  "Trade schools" qualify so long as the education is going to further the child's ability to move to financial self-sufficiency in life.  Some courses of training, however, won't qualify in all circumstances: DeVry Institute of Technology qualified in one case as "an education at the college or university level"  In re: Marriage of Oldham, 222 Ill.App.3d 744, 165 Ill.Dec. 206, 584 N.E.2d 385.  

The pre-1/1/16 law did not include the words "vocational . . . or other training."  Thus, under that version of the law, the "Automotive and Diesel College" did not qualify as part of the "college and professional education expenses of the children" (the wording of that version of the law).   In re: Marriage of Holderrieth, 181 Ill.App.3d 199, 129 Ill.Dec.896, 536 N.E.2d (1st Dist., 1991).   Today, the "Automotive and Diesel College" would probably qualify if it were still in business.

 

The Child's Share:  The law does not give kids a free ride – they are expected to apply for financial aid and take other steps to help keep costs down.   Indeed, one court has said "the children themselves have an obligation to lessen their parent's financial burden" by attending less costly state universities. In re: Marriage of Calisoff, 176 Ill.App.3d 721, 126 Ill.Dec. 183, 531 N.E.2d 810
(1 st Dist., 1988)

 

There is no requirement that the child have or maintain a good relationship with either parent.  Gibb v. Triezenberg, 188 Ill.App. 3d 695 (4th Dist., 1989); In re: Marriage of Drysch, 314 Ill.App.3d 640 (2d Dist., 2000). On the other hand, a child's relationship (or lack thereof) with the parents is a factor that courts have considered in some cases.  In re: Marriage of Hupe, 305 Ill.App.3d 118, 711 N.E.2d 789 (3d Dist., 1999).  The former husband had an annual income of approximately $90,000 and paid maintenance of $14,400 a year. He was ordered to pay for tuition, fees, and books, but nothing else (no transportation or room and board). His daughter was estranged from him and the daughter and mother together chose a private school that was more expensive than a state university.

Access to Transcripts, Records, and Grade Reports:  Non-custodial parents have a right to grade reports and student records. Even that informaiton may be restricted, however, in certain circumstances.  In one case, the father was required to pay 50% of his daughter’s college expenses, but was not allowed to know even the name of the college she attended.

 

Kids CAN'T Sue For Themselves: Illinois law used to permit children to sue their divorced parents for college expenses.  The right depended on the court's interpretation of the language of the divorce agreement (assuming there is one).  The child could boot-strap a case based on third-party-beneficiary standing.  That rule is no more.  The 2016 changes to Illinois' divorce law expressly put an end to children establishing third-party-beneficiary standing.  750 ILCS 5/513(i).

 

Personally, I find this part of the law unconstitutional.   The Illinois Constitution says:

 

SECTION 16. EX POST FACTO LAWS AND IMPAIRING CONTRACTS No ex post facto law, or law impairing the obligation of contracts or making an irrevocable grant of special privileges or immunities, shall be passed.

It seems to me that this law "impairs the obligation of contracts."  There are plenty of cases where the parents agree in the divorce to provide for college.  Later, they may have an incentive to not abide by that agreement.  It is the child who suffers in such situations . . . and the law now expressly prohibits relief.

 

Imagine a case where a couple in an abusive relationship divorces and th abusive husband, to achieve a favorabl property and maintenance settlement, agrees to pay for all of hte children's college expenses.  When the time comes for college, the former husband merely reactivates the abuse and coerces the mother to not file a claim for college contribution.  Th father could even tell the mother "College will cost me $300,000 -- I'll pay you $100,000 to not file a claim."  Under the law, thre is nothing the child can do to right thiese wrongs.

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