Department of Human Resources v. Jones

Pope, Chief Judge.

We granted this discretionary appeal to reemphasize the requirement that changed circumstances must be shown before an existing child support award may be modified. The trial court in this case ruled that: (a) its prior order in a legitimation proceeding validly decreased the existing child support obligation of Jones (the father) from $615 a month to $500 a month, and (b) the mother had to repay the father $1,955 (the difference between the two figures over seventeen months). We do not agree that the trial court’s prior order validly decreased the father’s child support…