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Elizabeth E. Ivey Goodrich v. John Exera Goodrich, Jr.

Tenn. Ct. App.April 26, 2018No. M2017-00792-COA-R3-CV
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Case Details

Judge(s)
Judge W. Neal McBrayer
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
Appeal from trial court's denial of motion to modify child support obligation

Related Laws

No specific laws identified for this ruling.

Outcome

Appellate court affirmed the trial court's determination that the father was voluntarily underemployed and upheld the child support obligation without modification despite his job loss and claimed inability to find comparable employment.

Excerpt

As part of a divorce proceeding, the trial court ordered a father to pay child support. Within two months thereafter, the father lost his job as a finance manager for an automotive dealership. The father filed a motion to modify his child support obligation and took a job in another field, making significantly less money. The father claimed that a more lucrative job was not available to him because he only had a high school education. And he did not wish to pursue another job as an automotive dealership finance manager due to the long hours, pressure, and deleterious effect of the job on his health. The mother opposed the motion to modify, claiming that the father was voluntarily underemployed. The trial court agreed. On appeal, the father challenges only the court's determination that he was voluntarily underemployed. After a review of the record, we affirm.

What This Ruling Means

**What Happened:** A father who worked as a finance manager at an automotive dealership lost his job two months after a court ordered him to pay child support during his divorce. He then took a lower-paying job in a different field and asked the court to reduce his child support payments. He argued that he couldn't find another high-paying job because he only had a high school education and didn't want to work at car dealerships anymore. **What the Court Decided:** Both the trial court and appeals court ruled against the father. They determined he was "voluntarily underemployed," meaning he was deliberately choosing to earn less money than he could. The courts refused to lower his child support payments, even though he had lost his original job and was making significantly less money. **Why This Matters for Workers:** This case shows that courts will look closely at whether someone is genuinely unable to find comparable work versus choosing to avoid certain types of jobs. Even if you lose your job, courts may not accept career changes that result in much lower pay if they believe you're deliberately limiting your job search or refusing suitable work opportunities. This can have serious financial consequences, especially when legal obligations like child support are involved.

This summary was generated to explain the ruling in plain English and is not legal advice.

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