Kronforst v. Kronforst
Remedy for arrearage in alimony is contempt, not a money judgment.
Remedy for arrearage in alimony is contempt, not a money judgment.
Remedy for arrearage in alimony is contempt, not a money judgment.
Court can order a party to put up security for future child support if there is a history of arrears.
Father was still under obligation to pay past due support after all kids had turned 18. Thus, income tax refunds can be seized.
Criminal rules for appeal, not civil rules, apply to contempt proceedings brought by FCC to enforce payment of child support, not right to court appointed counsel.
Laches does not apply to action to collect child support before statute of limitations begins to run when child attains majority. Also, W could collect COLA, even though she did not apply for increase for 5 years.
Contempt for child support arrears is still available as a remedy after child turns 18. Halmu decision is overruled.
Court cannot reduce arrears in child support under new statute. Retroactive applicability is not unconstitutional.
(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.
(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.