Freeman v. Groskopf
Annotate this CaseBased on genetic testing, Michael was found to be Child's father. The district court awarded sole custody to Jessica and ordered Michael to pay monthly child support. Michael subsequently requested that the court modify his child support, claiming that he had entered school full time and had no income. The court concluded that there had been a material change in circumstances but that Child still required support. The court then calculated a lower child support based on Michael's earning capacity. Jessica later sought to modify Michael's child support obligation. After a trial, the court increased Father's child support based on his new earning capacity. Both parties appealed. The Supreme Court affirmed, holding that the district court did not err in (1) finding a material change in circumstances; (2) calculating Michael's child support obligation; (3) refusing to make the modification retroactive; and (4) declining to order Michael to contribute toward childcare expenses.
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