March 2016 | 371 P.3d 744, 2016 COA 36 (Co. Ct. App. 2016)

In re Marriage of Gross and Gross (Colorado 2016)

When a parent voluntarily relinquishes parental rights, the obligation to support the child does not end until a final order of relinquishment is entered. In this case, § 14-10-122(5), C.R.S. 2015, could not be used to retroactively modify the child support order. For this statute to apply, the modification must have been filed under that statutory section, and there must be a change in physical care of the child. That was not the situation in this case as the child had already been living with the mother for an extended period of time.

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