In re the Dissolution of the Marriage of Annala

Appellant, the father of four children who are in the custody of their mother, moved to decrease child support payments from $225 per month per child to $150 for the three youngest children and to have the eldest, then 18, declared emancipated.1 After he filed the motion, but before the hearing, he sua sponte reduced his monthly support payments to $450. At the hearing, with no prior notice to respondent, he asked the court to credit against his support obligations certain amounts previously paid to the mother which he designated "voluntary excess child support payments.”

At the hearing, at…