In re Marriage of Mihm
Annotate this CaseMelissa and Scott Mihm entered into a stipulation and agreement for dissolution of their marriage. The stipulation included an agreement to a child support amount below what was provided by the child support guidelines (the guidelines). The district court incorporated the stipulation into its decree of dissolution. Scott later filed a motion to modify the divorce decree, and Melissa counterclaimed seeking an increase in child support. The district court concluded (1) there had been no substantial change in circumstances justifying a modification of Scott’s child support obligation, and (2) the agreement, which was made by the parties with full knowledge that the child support was not based upon the guidelines, should not be modified unless “for the direst of needs.” The Supreme Court reversed and remanded on the issue of child support, holding (1) the original child support order did not provide a proper basis on which to base a decision on modification of child support because it was not consistent with law or rules governing child support; and (2) Melissa showed there had been a substantial change in circumstances since the entry of the underlying decree, warranting a child support modification.
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