In re Rohdenburg

Summary

The New Hampshire Supreme Court reviewed a child support modification order that increased the respondent's obligation without addressing his request for a downward modification. The court held that the marital master committed clear legal error by accepting the petitioner's incomplete financial affidavit and by failing to make required findings concerning the economic consequences of the petitioner's remarriage. The judgment was reversed and remanded.

Holdings

1. Superior Court Rule 197 mandates full disclosure in every section of the financial affidavit at a hearing to modify child support, and the marital master committed clear error by accepting and relying on the petitioner's incomplete affidavit.
2. The master committed legal error by failing to make written findings addressing the respondent's claim that the parties' economic circumstances had substantially changed after the petitioner's remarriage.

Questions Presented

1. Whether the marital master committed clear error by accepting and relying on the petitioner's incomplete financial affidavit in a child-support modification proceeding.
2. Whether the marital master erred by failing to address the respondent's request for a downward modification based on a substantial change in the parties' economic circumstances following the petitioner's remarriage.

Disposition

reversed_and_remanded