Missouri Court of Appeals, Eastern District / Jan 22, 2019
John M. Hark, Respondent, vs. Amy M. (McKinney) Hark, Appellant.
Mother filed a motion to modify child support and child custody. The trial court modified child support using an outdated Form 14 and denied the physical custody modification, finding no substantial change in circumstances. The appellate court reversed and remanded the child support modification, instructing the trial court to use the current Form 14 and follow the two-step Woolridge procedure. However, the court affirmed the denial of the physical custody modification, concluding that Mother failed to demonstrate the trial court's finding of no substantial change was against the weight of the evidence.