St. Lawrence County Support Collection Unit v. Laneuville

Summary

The court affirmed a finding that the respondent willfully violated a prior child support order. The petitioner’s investigator established noncompliance, shifting the burden to the respondent to provide competent, credible evidence of an inability to pay. The respondent’s medical evidence, including testimony based primarily on subjective complaints without objective testing, was insufficient to meet that burden.

Holdings

1. After petitioner established respondent’s noncompliance with the prior support order, respondent failed to provide competent, credible evidence demonstrating that he was unable to make the required payments.
2. The finding that respondent willfully violated the prior support order was warranted.

Questions Presented

1. Whether respondent established a legally sufficient inability to make the required child-support payments.
2. Whether the evidence supported a finding that respondent’s violation of the support order was willful.

Disposition

affirmed