New York Family Law Snippets

The trial court is justified in increasing child supportcan be had only as to those installments accruing
if the needs of the child and the earnings of thesubsequent to due notice by the moving party of
supporting parent have increased since thethe motion for modification. Support payments
judgment granting child support was entered.may be modified only as to installments accruing
Where a former spouse's ability to pay childafter the party moving for modification has given
support is shown, the fact that the children havedue notice.
grown older and the cost of living has risen arePleadings
proper bases for establishing increased need. TheWhere petitioner sought modification of divorce
increase in the children's needs must be balanceddecree to compel ex-spouse to support the
against the relative ability of the parents toparties' mentally disabled child after she attained
provide for them, and where a change hasmajority; the petition adequately asserted a
occurred which creates a substantial imbalance"change in circumstances" based on the child's
between the child's needs and the parent'scontinuing handicap after attaining majority;
support capabilities, modification is required. Thehowever, it may not have been necessary to
increased needs of the child may be establishedplead a "change in circumstances" under this
by the child's growing older and the increase in thesection since there may be a substantive
cost of living established by the expert testimony.obligation to support a mentally disabled child in
New or changed conditions are necessary to750 ILCS 5/513, unrelated to the terms of any
warrant a change in support payments, andprior divorce decree.
increased needs of children may be presumedRetroactivity
from the fact that children have grown older andChild support payments may be modified only as
the cost of living has risen. An increased into installments accruing after the party moving
support payments is warranted when thefor modification has give due notice. A
evidence establishes that the needs of themodification for child support 20 years after the
children have increased, and the means of thedivorce could not be applied retroactively. The
father have also increased so as to enable him toquestion of whether modification of child support
contribute additional sums to his children's support.should be retroactive is within the discretion of
Noticethe trial court.
In General Modification of child support payments