Background
The parties divorced in 2016 and share joint legal and physical custody of their three children. A 2017 consent modification, entered after Mother moved to Georgia, designated Father’s Missouri home as the children’s primary residence and ended Father’s child-support obligation. Father remained responsible for most ordinary and extraordinary child-related expenses, while Mother was to contribute $150 monthly toward activities.
After Mother stopped making that contribution in 2024, Father sought modification. At trial, the parties stipulated that Father’s gross monthly income had fallen from $13,335 in 2017 to $10,254, while Mother’s had risen from $2,083 to $7,425. Father also testified to increased costs for the children’s food, clothing, phones, and health insurance. The circuit court adopted Father’s Form 14, ordered Mother to pay incremental support of $1,026 for two children and $728 for one child, and applied a six-percent overnight-visitation credit.
The Court’s Holding
The appellate court affirmed the modification judgment except that it dismissed Mother’s challenge to the presumed child-support amount for deficient briefing. Father’s detailed testimony regarding increased child-related costs, coupled with Father’s decreased income and Mother’s substantially increased income since the 2017 modification, was substantial evidence of a substantial and continuing change in circumstances under Missouri law. Receipts, invoices, and similar documentation were not required.
The court declined to review Mother’s challenge to the presumed child-support amount because her point relied on was multifarious and lacked record citations supporting preservation. It also rejected Mother’s Form 14 argument. The adopted Form 14 properly supplied incremental amounts for two children and one child, and the trial court had discretion to use a six-percent overnight credit based on the parenting time Mother actually exercised with the children.
Key Takeaways
- Detailed testimony can establish increased child-rearing costs without supporting receipts or invoices.
- Changed parental incomes and increased children’s expenses may together support child-support modification.
- An appellant’s multifarious point relied on and inadequate preservation citations can forfeit appellate review.
Why It Matters
The decision reinforces that Missouri courts assess changed circumstances from the last modification judgment, not from an intervening date selected by a party. It also confirms that Form 14 overnight credits may reflect actual parenting time rather than the time nominally available under a parenting plan.