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Strunk v. Strunk

The trial court erred in granting the father a $200 travel deviation without entering the required written findings in his action for a downward modification of child support.

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Monica P. Strunk and Martin B. Strunk were married in 1996 and had three children before divorcing in 2008. The husband sought a downward modification of child support in 2009, which the trial court granted in November 2012. In this direct appeal, the wife challenges five of the trial court’s rulings related to child support. We uphold the trial court’s decision granting the downward modification, with the exception of the grant of a $200 travel deviation to the husband, but reverse the part of the order specifying how the husband was to satisfy the $96,000 he owed in back child support. Accordingly, we affirm in part and reverse in part.

Following a bench trial in the initial divorce action, the trial court entered a final judgment on September 12, 2008, awarding the wife custody of the three children. In its order, the trial court imputed an annual income of $75,000 to the husband and determined that the husband earned 80 percent of the couple’s combined income. The husband was ordered to pay $2,001.60 per month in child support and $400 per month in permanent alimony for three years. After the husband failed to make child support or alimony payments, he was incarcerated for five months in 2009.

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