Newman v. Newman

BECK, Judge:

The issue in this case is whether the enactment of the statewide child and spousal support guidelines1 constitutes a change of circumstance in and of itself so as to permit the trial court to consider modification of a prior support order. We hold that the enactment does not. Since the sole reason for the trial court’s reconsideration of the prior support order was the enactment of the guidelines, we reverse the trial court.

*110In considering whether the promulgation of the statewide support guidelines constitutes a material and substantial change of circumstances which alone can…