In re Marriage of Nelson
Supreme Court of Iowa
570 N.W.2d 103 (Iowa 1997)
Scott Nelson (defendant) and Jane Nelson (plaintiff) divorced in 1989 with two children, while Scott was still in law school; the decree set his child support at $137.50 per month. The court raised it to $425 in 1993 at Jane's request. In 1995 Jane sought another increase, showing Scott's income had grown from $15,000 in 1991 to $38,524 in 1994. Scott argued car payments and law-school loans left him unable to afford more, claiming monthly expenses of $2,150 (including the existing $425 support payment) against net monthly income of $1,846. The trial court raised his payment to $695, and Scott appealed.
Whether a court may modify a child-support order based on a substantial change in the circumstances of one or both parties.