Hunt v. Hunt
Court of Appeals of Oregon
242 P.3d 682 (2010)
Mr. Hunt (plaintiff) was ordered to pay $392 monthly in child support under the Hunts' 2000 dissolution decree; after the couple's young son died in 2002, Mr. and Mrs. Hunt (defendant) reached an oral agreement to reduce the payment to $200 monthly, but Mr. Hunt never sought a court order formalizing that modification. Years later, once the Hunts' daughter turned 18, Mrs. Hunt filed an arrearage claim seeking the unpaid difference between the original $392 obligation and what Mr. Hunt had actually paid; the trial court denied Mr. Hunt's request for relief from the arrearage claim, and he appealed pro se.
Whether an oral agreement between divorced parents to modify a court-ordered child-support obligation is enforceable without an accompanying court order formally modifying the judgment.