Krohn v. Krohn (Mississippi 2020)

A court must approve any custody change. Without a court order, there may be no right to support. In this divorce, the mother was awarded primary custody of the child. The father was ordered to pay support and alimony. Post-divorce litigation regarding custody and child support began almost immediately. The father lost his high paying job and requested a modification. At a hearing, the chancery court found the father in contempt for failure to pay support, set purge conditions, entered a judgment for arrears, and reduced his child support obligation going forward. The father filed a Motion to Alter or Amend The Amended Judgement. He argued the chancery court should have ordered the Mother to pay him support for a brief period of time the child resided with him. The chancery court denied the motion, and the father appealed. The appellate court affirmed the decisio. It found the parents agreed that their daughter would live with the father for a few months, and there was no court order to sanction this change or that ordered the mother to pay support. The chancery court relieved him of his support obligation for this time period.