In re the Marriage of Winner

Mother appeals from a trial court order denying her motion to increase child support. The threshold issue is whether mother sustained her burden of proving a change of circumstances.

The decree was entered in 1975. Mother was awarded custody of the parties’ child. Father was ordered to pay nominal child support and the child’s medical and dental expenses. The decree was modified by stipulation in 1977 to provide that father would pay $80 monthly support.

At the hearing in December, 1981, mother testified that the support needs of the child had increased substantially since 1977. By her…