## Facts

- Christopher M. Gambla and Kimberly K. Woodson married in 2002 and later lived in Illinois with Woodson’s son from a prior marriage.
- Their child, Kira Marie, was born in 2002; Kira is biracial (white father, Black mother).
- In 2003, Gambla petitioned for dissolution and sought sole custody; Woodson counterpetitioned and also sought sole custody.
- The circuit court conducted an extended evidentiary trial over multiple days, including testimony from the parties, experts, and character witnesses.
- The circuit court dissolved the marriage and awarded sole custody to Woodson, with substantial visitation for Gambla.
- In explaining its ruling, the circuit court stated Kira’s biracial status was relevant and that Woodson could provide cultural knowledge Gambla could not, while also stating custody was not awarded solely because Woodson is an African-American woman.
- Gambla appealed pro se, challenging the best-interests determination and arguing the trial court improperly considered race.

## Issues

1. Whether awarding sole custody to Woodson was against the manifest weight of the evidence or an abuse of discretion under Illinois’s best-interests standard.
2. Whether the trial court improperly relied on race in the custody determination by treating the child’s biracial status and the parents’ races as a basis for awarding custody.

## Decision

- The appellate court affirmed the custody judgment awarding sole custody of Kira to Woodson.
- The court held the best-interests findings were supported by the evidentiary record and were not an abuse of discretion.
- The court held the trial court did not award custody on the basis of race; references to the child’s racial and cultural background were treated as part of a broader best-interests analysis, not as a dispositive criterion.

## Legal Principles

- Illinois custody determinations turn on the child’s best interests under the statutory factors; appellate review is highly deferential and reverses only for abuse of discretion or findings against the manifest weight of the evidence.
- Trial courts receive substantial deference in custody cases because they observe witnesses and assess credibility in fact-intensive disputes.
- A court may not award or deny custody solely on the basis of race; however, a child’s cultural background and a parent’s ability to support the child’s racial and cultural identity may be considered as one factor among many, so long as race is not determinative.

## Conclusion

The appellate court upheld a sole-custody award to the mother, concluding the record supported the best-interests determination and that the trial court’s discussion of the child’s biracial status reflected a permissible consideration of cultural background within a multi-factor custody analysis rather than an impermissible race-based decision.


In re Marriage of Gambla & Woodson, 853 N.E.2d 847 (Ill. App. Ct. 2d Dist. 2006)