Kerry Glew v. Robert Glew

Summary

The court affirmed an arrearage judgment enforcing a divorce judgment that required annual recalculation of child support under the guidelines in effect when the parties entered their settlement agreement. It held that the automatic-adjustment provision was enforceable and did not violate public policy because the parties agreed to it, it used multiple income-related factors, and either party could seek modification. The court also held that laches did not bar the arrearage claim because the delay was explained by Robert's refusal to provide required financial information.