Ivory v. Albert (Mississippi 2020)

A child support obligation may be terminated due to a child’s clear and extreme actions. The father filed to end his support obligation to the child. He alleged the child would not see him and didn’t want a relationship with him. The trial court ended the support. The mother appealed. The appellate court reversed the decision, finding the trial court used the right standard but didn’t correctly apply the standard to the facts. The appellate court found no evidence of the type of clear and extreme behavior that would justify terminating the support obligation. Mississippi case law contains examples of the type of behavior that is considered clear and extreme such as a refusal to visit based on allegations of abuse. The appellate court remanded the case to determine the ongoing support obligation.