MacKowiak v. Harris, 146 Idaho 864

Summary

The Idaho Supreme Court affirmed an order reducing a father's child support obligation to zero during his incarceration and requiring the parties to seek modification after his release. The court held that the mother could not challenge the reduction on appeal because she had not opposed it in the trial court. It further held that the trial court did not abuse its discretion by declining to automatically reinstate the prior support amount upon the father's release.

Holdings

1. MacKowiak could not challenge the reduction on appeal because she did not oppose that modification in the trial court.
2. The trial court did not abuse its discretion by requiring the parties to seek a new child support determination after Harris's release rather than automatically reinstating the prior award.

Questions Presented

1. Whether the district court erred in affirming the reduction of Harris's child support obligation to zero because he was incarcerated.
2. Whether the district court erred in affirming the trial court's refusal to automatically reinstate the prior child support award upon Harris's release from incarceration.

Disposition

affirmed