In re Marriage of Piaskoski v. Piaskoski
(1) Husband showed change in circumstances to modify child support. (2) Court erred in not giving husband credit against arrears for payments of debts and direct expenses.
In re Marriage of Kuchenbecker v. Schultz
(1) Orders regarding payment of health care expenses for minor children are in the nature of child support and can be modified under sec. 767.32. (2) Estoppel does not apply as court can order health care expense responsibility without agreement of parties. (3) Court must make proper findings of need/ability before changing order.
Parker v. Parker
Incarceration for intentional crime is not a substantial change in circumstances warranting a modification of child support.
In Interest of A.L.W.
Holding that the court can consider the resources of a non-liable spouse in determining a liable person’s ability to pay for a dependent relative’s care is consistent with Poindexter and with Burger.
In Re Marriage of Abitz v. Abitz
(1) Marital property principles of income are not to be considered in child support issues. (2) Use of percentage standards are purely discretionary in revision actions. (3) If court chooses to apply percentage standards, gross income is calculated as if parent remained single. (4) Circuit court can consider parent’s earning capacities and total economic circumstances.
In Re Marriage of Schulz v. Ystad
(1) Sec. 767.32 (1m) is prospective only and is applicable only to order or judgment made after August 1, 1987 (2) Credits against child support can be granted if made under the compulsion of the circumstances or with the implied or express consent of the payee.
In Re Marriage of Weston v. Holt
In proceeding to modify child support, a trial court is not mandated to apply the percentage of income standard. However, if the court does not apply it, the record must clearly show that the trial court considered the payor’s total economic circumstances.
In Re Marriage of Ondrasek v. Tenneson
Stipulation waiving or putting a limit on child support violates public policy.
In Re Marriage of Rummel
Equitable credit may be reimbursed from future support, as well as set off against arrears. Husband entitled to equitable credit where child went to live with him, but court erred by not requiring sufficient proof of definitive and specific expenditures.
In Re Marriage of Miller v. Miller
(1) No abuse of discretion in applying percentage to father’s income only as wife’s income does not count under WUMPA (2) Court can consider costs of replacing wife in business in that it would decrease husband’s profits (3) Court can consider depreciation costs as business expense as part of the overall economic circumstances.