Olmstead v. Ziegler
Supreme Court of Alaska
42 P.3d 1102 (2002)
After divorcing, attorney Olmstead (plaintiff) agreed to cover certain child-related costs without formal support obligations while his income was higher than ex-wife Ziegler's (defendant's); over time his solo law practice declined due to his own reduced productivity and workload, and he eventually closed it entirely to return to school and become a teacher, then sought a reduction in his modest existing support payment based on this drop in income. The trial court denied the reduction, finding his underemployment and career change voluntary, and Olmstead appealed.
Whether a court may deny a requested reduction in child support where the payor's decreased income resulted from voluntary conduct, including a deliberate career change.