Robeson County Enforcement Unit v. Harrison (North Carolina 2018)

A substantial change of circumstances must occur for a child support order to be modified. The father appealed an order modifying his support arguing that there was no substantial change of circumstances. His income had increased, but it increased some time ago. In fact, the parties agreed to the previous order, and his income had already changed at that time. The court of appeals disagreed. It noted that the change in father’s income was not disclosed in the earlier order. It found that the mother testified to changes in her situation, which coupled with the increased income, supported the modification of support.