Missouri Court of Appeals, Western District / Apr 16, 2019
Erika Johnson vs. Zjohn Riley
Erika Johnson appealed the circuit court's judgment modifying child custody and child support, which had granted Zjohn Riley joint legal and physical custody and reduced his child support obligation. The circuit court had entered its judgment after Mother failed to appear. The appellate court reversed, finding insufficient evidence of a change in circumstances related to the child or custodian to warrant the custody modification. Consequently, the child support modification, being intertwined with custody, was also reversed. The court also denied Mother's jurisdictional point due to an insufficient record on appeal.