Kristine K. Lauer, Plaintiff and Appellee v. Mark A. Lauer, Defendant and Appellant

Summary

The court held that the district court improperly applied a material-change-in-circumstances requirement to a child-support modification motion filed more than one year after the original order. Because the court failed to apply the child-support guidelines and did not make adequate findings supporting imputed income, the support award was reversed and remanded for recalculation. The court affirmed the attorney-fee award because fees were authorized as a remedial contempt sanction and no abuse of discretion was shown.