State, Department of Social Services, Division of Child Support Enforcement v. Houston

ANN K. COVINGTON, Judge.

The State of Missouri, Department of Social Services, Division of Child Support Enforcement (the division), and Sheila Rae Phillips appeal the trial court’s judgment setting aside an administrative order modifying child support because the order lacked judicial approval. The Missouri Court of Appeals, Southern District, affirmed the judgment. Upon the division’s application for transfer, this Court granted transfer. Reversed.

Subsection 1 of section 454.496 1 set forth the initial requirements for administrative modification of child support orders. The record reflects…