J. Harris

The mother brought a motion to change a 2015 final order for child support, seeking retroactive and prospective increases.

The father had failed to provide annual financial disclosure as required by the 2015 order, and his income had materially increased.

The court applied the Colucci framework, finding the father engaged in blameworthy conduct by failing to disclose his income increases.

The court imputed income to the father based on minimum wage plus self-employment earnings as a disc jockey.

Retroactive child support was ordered back to January 1, 2020, resulting in arrears of $4,137, alongside ongoing monthly support and proportionate contributions to section 7 expenses.

The children's aid society sought an order for extended society care for a four-year-old child diagnosed with autism spectrum disorder.

The parents, who had a history of severe intimate partner violence, substance abuse, and criminal charges, sought a supervision order placing the child with the paternal grandmother.

The court found the child remained in need of protection due to the parents' ongoing volatile relationship and inability to meet the child's significant special needs.

The court rejected the kinship plan, finding the paternal grandmother lacked the capacity and insight to care for the child.

The child was placed in extended society care with limited supervised access for the parents, who were designated as access recipients rather than access holders to avoid impairing future adoption opportunities.