The father brought a motion to terminate child support for his 19-year-old daughter.
The mother opposed and sought a retroactive increase in child support and arrears, arguing the father failed to disclose income increases.
Applying the Colucci framework, the court found the father's failure to disclose income constituted blameworthy conduct and ordered retroactive child support to March 2018, three years prior to formal notice.
The court declined to credit the father for discretionary payments made outside of child support.
Ongoing child support was ordered to continue as the child was enrolled in university.
