Tierney v. Berger


2012 WI App 91, 343 Wis. 2d 681, 820 N.W.2d 459 (WI Ct. App. 2012)


Evidence of substantial change in circumstances was overwhelming where, among other things, the last order was more than 33 months earlier; teenagers had greater expenses; father moved to Illinois making placement less likely; father was estranged from one of the children; both parties were remarried and had two more children; mother and her husband were not employed, and father was making substantially more money.  Any one of these reasons would “probably have qualified for a substantial change in circumstances.”

[ Full Opinion ]