Carlsen v. Berry

Opinion

DAVIS, J.

In the course of responding to Donald Carlsen’s motion to modify their visitation agreement, Lynnette Berry moved to modify Carlsen’s child support obligation. Based on the declarations of the parties, the trial court awarded an increase in child support from $950 to $2,029 per month. Without benefit of a statement of decision, Carlsen appeals. In the *215published part of the opinion, we agree the trial court improperly credited Berry with a hardship allowance (Fam. Code, §§ 4071-4073; undesignated section references will be to this code), but reject Carlsen’s claim that the…