Nave-Free v. Free, 2019 UT App 83 (May 16, 2019)

In this domestic case, the appellant argued that a post-decree reduction in medical expenses should result in a decrease of child support.  The court of appeals clarified that the statute at issue, which allowed an adjustment to child support based on material changes in medical needs of a child, was directed at changes to “underlying medical conditions.”  Id. ¶¶ 17-18.  Because the appellant addressed only costs of care, as opposed to changes in the children’s medical needs, the district court did not err in denying his petition to modify child support.