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McCraw v. McCraw

Citations: 759 So. 2d 519; 2000 Miss. App. LEXIS 207; 2000 WL 523173Docket: No. 1999-CA-00049-COA

Court: Court of Appeals of Mississippi; May 2, 2000; Mississippi; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by Lester McCraw against a Chancery Court judgment that awarded his former wife, Gloria McCraw, delinquent payments and increased her periodic alimony. The parties, divorced in 1994, had agreed to child support and alimony terms, which Mr. McCraw allegedly failed to meet, prompting Mrs. McCraw to file for contempt in 1998. The chancellor found Mr. McCraw in arrears and increased alimony from $200 to $300 per month, while terminating child support due to the child's emancipation. On appeal, the court found the chancellor erred in increasing alimony without evidence of changed circumstances, as Mrs. McCraw received a pension lump sum and was employed part-time. The appellate court upheld the continuation of the original alimony amount, as Mr. McCraw failed to substantiate his claim of financial inability to continue payments. The judgment was affirmed in part and reversed in part, reinstating the original alimony amount, with costs of appeal imposed on the appellee.

Legal Issues Addressed

Effect of Child's Emancipation on Support Obligations

Application: The court terminated the child support obligation due to the child's self-sustaining status, acknowledging the child's emancipation.

Reasoning: The chancellor found Mr. McCraw in arrears and awarded the delinquent amounts but terminated child support due to the child's emancipation.

Enforcement of Delinquent Support Payments

Application: The chancellor correctly found the appellant in arrears for child support and alimony, awarding the delinquent amounts to the appellee.

Reasoning: The chancellor found Mr. McCraw in arrears and awarded the delinquent amounts but terminated child support due to the child's emancipation.

Modification of Alimony

Application: The appellate court found that an increase in alimony requires credible evidence of changed circumstances, which was absent in this case.

Reasoning: The appellate court determined that the chancellor was manifestly in error in increasing the alimony without credible evidence of changed circumstances justifying such an increase.

Termination of Alimony Obligations

Application: The court explained that alimony does not automatically terminate unless specific conditions are met, which were not present in this case, thus affirming the continuation of the original alimony obligation.

Reasoning: Periodic alimony does not automatically terminate unless specific conditions are met, which were not present in this case.