Lewis v. Lewis

JOANOS, Judge.

Carolyn Lewis appeals from an order modifying a final judgment of dissolution by reducing Anderson Lewis Jr.’s child support obligation. Carolyn argues that the reduction is improper without pleadings regarding same and evidence of changed circumstances. We agree and reverse.

Modification of child support is improper where there is no pleading requesting a modification of child support and no indication that financial information adduced at the hearing to prove arrearages and ability to pay would be considered by the trial court as a basis for modification. Smith v. Smith, 363…