- Court: Oregon Court of Appeals
- Area(s) of Law: Family Law
- Date Filed: 04-04-2012
- Case #: A146968
- Judge(s)/Court Below: Hadlock, J. for the Court; Ortega, P.J.; and Sercombe, J.
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.