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Moore v. McKinney

The trial court erred in making retroactive modifications to the child support terms that had been established by the parties' divorce decree and in failing to require the parties to share uninsured medical expenses for their minor child.

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The trial court granted Anthony Moore’s petition for modification of the child custody and support terms that had been established by a divorce decree. Moore, proceeding pro se, appeals and generally challenges the trial court’s determinations regarding Janeene McKinney’s child support obligations and other amounts owed to Moore. Because we conclude that the trial court made several errors in this respect, we vacate and remand for further proceedings.

The record1 shows that Moore and McKinney were divorced in 2002, when their children M. M. and D. M. were eight and four years old, respectively. McKinney was granted primary physical custody of the children, and Moore was ordered to pay child support until each child turned 18 years old or until the child finished secondary school, whichever came later, but in any case ending when the child turned 20 years of age. McKinney was required to provide health insurance coverage for the children, and the parties agreed to share the uninsured medical expenses for the children.

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