Marriage of Peters (Oatman) v. Peters
Failure to visit children by father is not a change of circumstances entitling mother to more child support without a showing of the financial consequences.
Marriage of Long v. Wasielewski
Percentage standards do not apply to post-judgment modification of child support.
In Re Marriage of Honore v. Honore
Stipulation maintaining specified level of child support notwithstanding subsequent reduction in income is enforceable and not contrary to public policy.
Marriage of Thibadeau v. Thibadeau
(1) Increased age of children alone is not sufficient for increase in child support – must show increased expenses. (2) AFDC, child support for child of previous marriage, education loans and grants are NOT income for purposes of child support.
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.