Harrell v. Harrell

We reverse the decision of the trial judge in this proceeding to modify child support based on the emancipation of an adult child. The party seeking modification has the burden of showing a significant change in circumstances, by substantial competent evidence. Bernstein v. Bernstein, 498 So.2d 1270, 1271-72 (Fla. 4th DCA 1986). The trial judge concluded that former wife had not met this burden, yet failed to recalculate monthly child support payments according to the requisite guidelines, the effect of which was to increase the amount of child support for the only remaining unemancipated…