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Parenting Plan Modifications Must Include Form 14 Specificity and Reference to Major Holidays

Updated: Oct 11, 2018

Olson v. Olson, SD 35239, 2018 WL 4292404, at *1 (Mo. Ct. App. Sept. 10, 2018)

Jack and Christine Olson married in Wisconsin in November 1996, had three children, and later moved to Newton County, Missouri, in June 2010.  The Olsons divorced in 2011.

Jack moved back to Wisconsin several months after the divorce.

In August 2015, Jack moved to modify his parenting time and child support, alleging substantial and continuing changes in circumstances due to his relocation to Wisconsin and the ages of the parties' children, who were 10 and 8 at the time.

Christine filed a counter-motion to modify, alleging continuing and substantial changes in circumstances, including an increase in the children’s financial needs, the cost of living, and Jack’s income, as well as the unfeasibility of the joint custody plan after Jack’s relocation.

Trial was held on October 2016, and the Court entered its modification judgment on July 24, 2017.  The Court’s order provided that:

  • There had been no substantial change in the children’s’ condition;

  • The “best interest of the children” would be served by modifying the parenting plan;

  • Father should pay an increase in child support.

The Southern District reversed and remanded the case, finding that:

  • Modifications to child support calculations MUST include a Form 14 calculation or some similar calculation of the rational for the change;

  • The parenting plan modification must address all holidays as prescribed in R.S. Mo. Section 452.310.8


  • Notable is the time lapse between when Jack Olson moved to modify the parenting plan (August 2015), when the trial Court ruled on the modifications (July 2017), and that a final outcome still has not occurred. While this timing is not atypical in any type of civil litigation, potential family law litigants should be aware that decisions about their children’s’ lives, when left to the Court, can take several years.

  • Also notable, some of the issues raised by Jack and Christine (the timing and sequence of travel and visitation for instance) were not even addressed by the trial court.  Potential litigants should also remember that family law trial courts may or may not rule on all the issues raised in a particular motion or trial.


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