Dixon v. Dixon (Mississippi 2018)

A Mississippi statute gives courts discretion to emancipate a child and terminate child support under certain circumstances. A judgment on arrears clears a parent of contempt so as to allow for a modification of support but the parent still has to show a substantial change in circumstances. The father appealed the chancery court order that did not emancipate his daughter and denied his request for modification of support. The Court of Appeals upheld the order. The Court found the evidence showed that the daughter still relied on the mother for financial support even though she no longer lived at home. The Court found that the chancery court erred in not allowing a modification because the father had unclean hands. However, in the order, the court also explained that no substantial change of circumstances existed so as to merit a modification.