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Bock and Bock

Summarized by: 

Date Filed: 04-04-2012
Case #: A146968
Hadlock, J. for the Court; Ortega, P.J.; and Sercombe, J.
Full Text Opinion: http://www.publications.ojd.state.or.us/Publications/A146968.pdf

Family Law: A 4% increase in income does not constitute an unanticipated or substantial change in economic circumstances that would justify a modification of a child support order.

Father appealed the trial court’s supplemental judgment changing the child support provisions of the stipulated general judgment of dissolution, which was issued in 2008. The supplemental judgment was based upon Mother’s filing of a motion to modify child support in 2009. After a May 2010 hearing, the trial court: increased Father’s child-support obligation from $500 to $1,192 per month; vacated Father’s reception of two of the three child dependency exemptions; and increased Father’s medical support obligation from 80% to 100% of health care costs. The trial court based its finding on Father's 4% income increase over 17 months. The Court of Appeals held that the 4% income increase was not an unanticipated or substantial change in economic circumstances that would justify a modification of a child support order. Reversed.