David B. v. Megan C. CA2/5
Respondent David B. (David) petitioned the family court to reduce child support payments he made to appellant Megan C. (Megan) for the benefit of their daughter. After a convoluted series of hearings over the course of a year, the family court—orally during a hearing—granted David’s request to reduce his child support payments. A minute order and Order After Hearing subsequently issued by the family court, however, indicated the family court denied David’s child support modification request. David later asked the family court to correct the written orders it issued as the product of clerical error, and the family court agreed. Megan now appeals, and we consider whether the orders were properly corrected on clerical error grounds, whether Megan was entitled to a statement of decision upon correction of the errors, and if so, whether the family court’s refusal to prepare a statement of decision warrants reversal.
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