In Re Marriage of Tozer v. Tozer
Refusal to modify support affirmed where husband quit his job before securing alternative employment.
Marriage of Wallen v. Wallen
Evidence insufficient that husband was failing to exercise capacity to earn to reduce ability to pay support.
In Re Paternity of R.L.M. v. T.J.W.
“Two-Tiered” order affirmed. Even with no shirking, trial court could base child support award on earning potential where H intentionally worked part time in order to go to school.
In Re Marriage of Roeling v. Roeling
Where shirking is found, change in circumstances is based on change in earning capacity.
Parker v. Parker
Incarceration for intentional crime is not a substantial change in circumstances warranting a modification of child support.
Zirngibl v. Zirngibl
Wife’s potential earning capacity is not an appropriate basis for determining maintenance in view of her testimony that she does not plan on teaching. A spouse is not disqualified from maintenance if he or she makes a career choice which results in reduced income.
In Re Marriage of Wikel v. Wikel
No abuse of discretion in ordering 8 years of maintenance in 25 year marriage – no abuse of discretion in refusing to find that wife is intentionally underemployed and does not use her ability to become self-supporting.
In Re Marriage of Voecks v. Voecks
Incarceration for intentional crime may be a substantial change in circumstances warranting modification of child support.
In Support of B.L.T.
Only actual receipt of AFDC is excluded from gross income.
Marriage of Van Offeren v. Van Offeren
Where voluntary reduction of support was well intended, court can still consider the reasonableness of the employment choice in light of the support obligation.