Marriage of Cohen
Annotate this CaseAfter Richard Cohen (Richard) filed a request to modify his child support and spousal support obligations, Lauralin Anderson Cohen (Lauralin) moved to dismiss Richard’s motion under the disentitlement doctrine as Richard was delinquent on his support obligations. The trial court granted Lauralin’s motion and on its own, conditioned the filing of any future modification requests on Richard being current on his support obligations. The Court of Appeal concluded the trial court did not abuse its discretion in granting Lauralin’s motion to dismiss, but erred in conditioning the filing of future modification requests on Richard being current on his support obligations.
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