Supreme Court of Arkansas
Marilyn Curry Troutman, Appellant v. Ronald Troutman, Appellee
April 20, 20172017 Ark. LEXIS 114
Summary
The court reversed and dismissed the circuit court's order reducing Ronald Troutman's child-support obligation because he failed to prove a material change in circumstances from the circumstances underlying the prior support order. The court held that the prior agreed order could not establish Troutman's baseline income and that his evidence did not permit a valid comparison with his earlier financial circumstances. The court also explained that child-support income is broader than taxable personal income and may include retained earnings and other funds available to support the child. Justice Womack and Chief Justice Kemp, dissenting, would have affirmed the modification based on the tax-return evidence and the circuit court's application of the governing administrative order.