In Re of Zikmanis

The petitioner, Audrey Zikmanis (wife), appeals a recommendation of the Master (Green, M.) approved by the Superior Court (Abramson, J.) modifying the parties’ child support obligation. She argues that the trial court erred in: (1) modifying a valid support order as a sanction for her conduct; and (2) modifying the support obligation retroactively and prospectively when no request for modification was pending, and without obtaining current financial affidavits or making requisite findings as to the parties’ abilities to pay. We vacate and remand.

The record before us evidences the following…