Alaska Supreme Court
Guy Alan Berry Jr. v. Colleen Marie Coulman
April 26, 2019440 P.3d 264
Summary
The Alaska Supreme Court affirmed the modification of Berry's child support obligation. It held that Alaska retained subject matter jurisdiction because Berry was domiciled in Alaska and that the superior court, not only the child support agency, could modify the existing order. The court also held that Berry's income changes established the required material change in circumstances and that the one-day retroactive error was de minimis and did not require remand.