In Re Marriage of Kates

The central issue in this appeal is whether, under section 7(b—5) of the Illinois Parentage Act of 1984 (Parentage Act) (750 ILCS 45/7(b—5) (West 2000)), deoxyribonucleic acid (DNA) test results disproving paternity are a condition precedent to the filing of an action to declare the nonexistence of the parent and child relationship. The appellate court held that such test results are a condition precedent to the filing of a section 7(b—5) action, and reversed the judgment of the circuit court of Macon County in favor of Mark Kates, who had filed a section 7(b—5) petition 1 without first…