Galvin v. Galvin, S10A1104

*All courts mentioned are at the state level.

• Father petitioned for modification of custody and child support based on being unemployed.
• Downward modification of support that is retroactive to the date Father sought modification was not required, as Father only sought downward modification, and thus O.C.G.A. § 19-6-15(j) did not apply to keep child support from accruing.
• Trial court correctly imputed income to father, despite his involuntary unemployment, because evidence showed he was unemployed for a prolonged period of time, and he did not make significant efforts to gain employment.
• Trial court correctly declined to make a downward modification of Father’s obligation regarding child’s medical and dental expenses, as trial courts are not required to allocate the parties’ share of health care expenses at the same rate as their share of child support awards.
• Trial court need not address Father’s visitation suggestions when there is no evidence of material change in circumstances warranting modification of current custodial agreement.