Garza v. Garza, 288 Neb. 213

Garza filed to modify child support and parenting time; district court found material change in circumstances due to Garza's move to Kansas and adjusted parenting/time arrangements.
Garza was previously ordered to pay $500/month child support and had alternating weekend visitation.
Garza moved to Lenexa, Kansas in 2010, leading to allegations that travel and scheduling affected visitation.
Trial court determined the move was voluntary but found a material change in circumstances; transportation was limited to meet Garza at a location after Garza's employment resumed.
The court reduced Garza's child support to $305/month and ordered Faust Aman to pay $2,500 in attorney fees; Garza’s request for further reductions and his own attorney fees were denied.
Garza and Faust Aman cross-appealed on several issues, including transportation, child support calculation, and attorney fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Visitation transportation arrangement law	Garza	Faust Aman	No error; court did not require immediate half-way transportation.
Child support calculation and change in circumstances	Garza	Faust Aman	Material change; reduction to $305/month affirmed.
Attorney fees awards	Garza	Faust Aman	Fees awarded; not an abuse of discretion.

Caniglia v. Caniglia, 285 Neb. 930, 830 N.W.2d 207 (2013) (related visitation transportation considerations in modification actions)
Finney v. Finney, 273 Neb. 436, 730 N.W.2d 351 (2007) (standards for modification of dissolution decrees)
Voichoskie v. Voichoskie, 215 Neb. 775, 340 N.W.2d 442 (1983) (guidelines for income deductions in support calculations)
Noonan v. Noonan, 261 Neb. 552, 624 N.W.2d 314 (2001) (permissible adjustments under guidelines for benefits/deductions)
Boamah-Wiafe v. Rashleigh, 9 Neb. App. 503, 614 N.W.2d 778 (2000) (evidence requirements for attorney-fee awards; preferred affidavits)
Watkins v. Watkins, 285 Neb. 693, 829 N.W.2d 643 (2013) (unclean hands doctrine applicability in modification cases)