Smith v. Edelman

Does a substantial postdivorce increase in the income of a noncustodial parent constitute a material change in circumstances warranting an increase in child support, where the children’s needs are well met and there is no material disparity in the standards of living between the custodial and noncustodial households? A judge of the Probate and Family Court answered the question in the negative, and denied so much of the wife’s complaint for modification as sought an increase in child support. We conclude that the judge did not abuse her discretion and affirm the judgment.

Background. When the…