Patricia Howard v. Delwin Mecham

This case involves a controversy over modification of the child support provision of a divorce decree. On appeal, Delwin Mecham contests an appellate decision of the district court upholding a magistrates finding that Mechams ex-wife, Patricia Howard, was entitled to a change in child support payments due to emancipation of one of the couples children. Mecham contends that the magistrate erred in concluding that emancipation of the child constituted a substantial, material and permanent change of circumstance warranting modification of his child support obligation, and that the magistrate erred by basing the increase in per-child support payments upon proposed -- but not then adopted -- Idaho Child Support Guidelines (hereinafter Guidelines). For the reasons explained below, we vacate the appellate decision of the district court, and remand this case with instructions consistent with our opinion.