Flannery v. Flannery

OPINION

EASTAUGH, Justice.

I. INTRODUCTION

Michael Flannery entered into an agreement in 1992 to pay child support significantly exceeding the minimum amount required by Alaska Civil Rule 90.3; in 1995 he moved to reduce his support payments, claiming a material change of circumstances under Rule 90.3(h)(1). The superior court denied his motion. We conclude that the superior court erred when it relied on a three-year average of Michael’s income to determine that he had not experienced a reduction in income. Accordingly, we reverse and remand.

II. FACTS AND PROCEEDINGS

Michael and Stephanie…