Biehl v. Hyde, No. 2021AP868 (October 18, 2022): Modification of placement affirmed where father had relocated much closer to his daughter, purchased his own home, obtained a new job that allowed him to work exclusively from home which reduces the need for childcare, married a woman who also works from home and with whom he…
Thompson v. Ouellette, 2023 WI App 7, 406 Wis. 2d 99, 986 N.W.2d 338: Newly enacted Wis. Stats § 895.044(5) retains the longstanding rule that sanctions for a frivolous appeal will not be awarded unless the entire appeal is frivolous.
Valadez v. Aprahamian, Nos. 2021AP1436, 2021AP994 and 2021AP1186: One contempt finding reversed where the trial court did not comply with the statutory requirements for nonsummary contempt. However, another summary contempt for interrupting the court affirmed as it occurred in the actual presence of the court, the contempt was for the purpose of preserving order, the…
Murphy v. Holland, No. 2020AP1802 (2021): Termination of maintenance when husband turns 65 is affirmed as within trial court’s discretion. The trial court considered all the statutory factors and the maintenance wife had already received, the retirement accounts transferred to her, and her life style including a “high end” condo in Mexico. The marital standard…
Golan v. Saada, 596 U.S. _____ (2022) (No. 20–1034). a district court must exercise its discretion to consider ameliorative measures in a manner consistent with its general obligation to address the parties’ substantive arguments and its specific obligations under the Convention.
RURESA order in Pennsylvania did not modify prior Wisconsin child support order and Wisconsin order continued to run.
Iowa support order was concurrent with Wisconsin order. It did not effect husband’s support obligation in Wisconsin.
Where divorce was in Virginia, mother and child now live in Wisconsin, father lives in Delaware, Wisconsin cannot modify child support under UIFSA based on payor’s request. Wisconsin can modify under UIFSA only if either the parties file a written consent or the petitioner seeking modification is a nonresident, the respondent is subject to personal jurisdiction and no one lives in issuing state.
While a trial court has authority to dismiss a UIFSA action for discovery violations, the law requires a finding of egregious conduct by the violating party as a prerequisite to the severe penalty of dismissal.
Articles from scholarly/legal journals on UCCJA and divorce.