September 2015 | 808 N.W.2d 905 (Neb. App. 2012)
Collins v. Collins (Nebraska 2012)
A material change in circumstance sufficient to justify modifying a child support order must exist at the time of trial, evidence must support the change, and it must be more than a temporary change. A court is permitted to consider a parent’s earning capacity, but earning capacity should only be used if there is evidence the parent can realize that capacity through reasonable efforts.
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