Williams v. Williams

Citations

• 2023 ND 240

Syllabus

Reopening the record is an evidentiary issue subject to the abuse of discretion standard. If the obligor fails to provide reliable information regarding his gross income, and that information cannot be reasonably obtained from other sources, the court must impute income and apply the method providing the greatest amount. District courts must use a source demonstrating statewide average earnings to determine the obligor's income for child support calculations if the obligor fails to provide sufficient reliable information for determining the obligor's income. Whether to award attorney's fees in conjunction with a discovery violation is generally within the discretion of the district court.