Miller v. Miller (Nebraska 2019)

A child support modification may be denied if the parent’s reduction in income is due to the parent’s own poor financial decisions. The father filed to modify his child support based on a reduction in income. The district court denied the modification, and the father appealed. The appellate court upheld the decision. It found the father’s income varied year to year. The court averaged the father’s income over two periods and found a decline. However, this isn’t the only factor to consider when reviewing an order for modification. The father’s financial records showed he chose to spend money on golf and restaurants rather than paying child support. The appellate court found the district court didn’t abuse its discretion in denying the modification.