Elissa Shanigan, Appellant v. Terrence Shanigan, Appellee

Summary

The Alaska Supreme Court reversed the superior court’s order reducing child support, finding that the Child Support Services Division’s income calculations were erroneous, that the reduction did not meet the statutory 15% threshold for a presumed material change, and that the father should have been required to file a sworn income affidavit. The reversal was based on a correct application of Alaska Civil Rule 90.3 and the clearly erroneous standard of review.