Beck v. Beck (Nebraska 2019)

To modify a child support order, a parent must show a substantial change of circumstances which occurred after entry of the most recent order and wasn’t contemplated when the order was entered. A change is a parent’s financial situation can qualify. The mother filed to modify the child support provision of the original divorce decree. She argued her income had decreased, and the father’s had increased. The district court denied her request. The mother appealed. The appellate court upheld the order. The appellate court found the evidence showed no substantial change. The evidence showed a decrease in father’s income. The father, a dentist, had brought in a partner and had sold an interest in his practice. He was still working the same amount, but under a different arrangement. Even with the decrease in come, he wasn’t seeking to lower his support. The evidence showed that the mother was earning less, but she was also working fewer hours.