Marriage of Jackson

Summary

The Court held that the motion to modify child support made the required threshold showing of changed circumstances, including a substantial reduction in the mother's income, health-related limitations, aging children and health-insurance concerns, and evidence suggesting increased income by the father. Because those allegations required factual development to determine whether the existing support order had become unconscionable, the District Court abused its discretion by denying discovery and an evidentiary hearing. The order was reversed and the matter remanded for discovery and a hearing.