Matter of Goehringer v. Vozza-Nicolosi

Appeal from an order of the Family Court, Westchester County (Arlene E. Katz, J.), dated April 6, 2015. The order denied the mother’s objections to so much of an order of that court (Christine Patneaude Krahulik, S.M.) dated December 24, 2014, as, after a hearing, granted the father’s petition for a downward modification of his child support obligation.

Ordered that the order dated April 6, 2015, is affirmed, without costs or disbursements.

To establish entitlement to a downward modification of a child support order, a party has the burden of showing that there has been “a substantial change in…