Marilyn Curry Troutman, Appellant v. Ronald Troutman, Appellee

Summary

The court held that Ronald Troutman failed to prove a material change in circumstances warranting reduction of his child-support obligation because he did not provide evidence establishing a valid comparison with the circumstances underlying the prior order. The court also explained that child-support income is broader than taxable income and may include retained earnings and other funds available to support a child. The modification order was reversed and dismissed, and the court of appeals opinion was vacated. Chief Justice Kemp and Justice Womack, joined by Justice Wood, dissented and would have affirmed the modification.