Johnson v. Johnson (KY) No 15% Change In Child Support Not Preserved For Appeal

Johnson v. Johnson, 232 S.W.3d 571 (Ky. App. 2007)

Dad appealed an order recalculating and increasing his child support. On appeal, Dad argued that it was error for the TC to review child support because Mom did not show a 15% change in the amount of child support due. Also, Dad argued that the TC abused its discretion in raising his child support because mom didn’t show a 15% increase. CA held the TC erred in not making any findings of fact but Dad failed to request the court make such findings and therefore failed to preserve the error for appeal.
Digested by Linda Dixon Bullock, Diana L. Skaggs + Associates