May 2018 | No. M2017-01137-COA-R3-CV (Tenn. Ct. App. 2018)

State ex rel. Lytle v. Webb (Tennessee 2018)

Adequate findings must support the determination of an arrearage amount. The father appealed an order setting arrears.  The arrears were determined in a modification order, but the state filed to alter/amend the arrears amount. The court amended the amount, and father filed to set aside this order. He argued that there was no evidence to support how the trial court calculated the arrears or interest amount. The appellate court agreed with the father. It could not determine how the trial court had calculated the arrears so the case was remanded for further findings.

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