Poe v. Poe

Kimberly Poe, former wife, appeals the granting of former husband’s supplemental petition for modification which reduced his child support obligation for the parties’ three minor children. She argues that the trial court erred in finding a substantial change in circumstances, failing to impute income to former husband, and imputing income to her.

To justify a modification of child support, a movant must show: (1) a substantial change in circumstances, (2) the change was not contemplated at the time of the divorce judgment, and (3) the change is sufficient, material, involuntary, and permanent.…