Hogan v. Eriksen
Opinion of the Court
When one parent seeks to increase the support obligations of the children based upon their increased needs, it is not necessary to show an unanticipated and unreasonable change in circumstances because the increase is predicated on the children’s
Here, no proof was offered as to the increased needs of the parties’ children. That the mother’s new family unit was suffering financial difficulties did not satisfy her burden of proving specific increased needs of the parties’ children which would warrant an increase in child support (see, Matter of Staffanel v Staffanel, supra; Matter of Adams-Eppes v Fulton, supra; Zucker v Zucker, supra; Matter of Miller v Davis, 176 AD2d 945). Miller, J. P., Copertino, Santucci and Altman, JJ., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.