Nielson v. Nielson (Nebraska 2021)

A parent who seeks to modify a child support order must show an unforeseeable material change of circumstances that occurred after the entry of the original decree. The parents agreed to child support in the initial decree, even though the amount didn’t match the child support worksheets attached to the order. The father failed to pay, and the mother filed for contempt. Subsequently, the father filed to modify his child support order based on a downturn in his business. The trial court denied the modification. The father appealed. The court of appeals affirmed the order finding the record contained ample evidence to support the denial. The father’s lifestyle belied his claim of a reduced income. Since the divorce, he had purchased a new house and car, remarried, and maintained a country club membership.