In Re the Marriage of Amethyst Nelson and Ryan Nelson Upon the Petition of Amethyst Nelson, and Concerning Ryan Nelson, 15-2100

Ryan and Amethyst Nelson divorced in 2013; Amethyst received physical care of three children and Ryan was ordered to pay $1,100/month in child support based on ~$60,000 yearly income as a Packaging Corp. supervisor.
Ryan left his Packaging Corp. night-shift supervisory job in 2014 to take a lower-paying daytime mechanic job (Inland) to spend more time with his children.
In 2015 Ryan changed jobs twice: he began EMT training, left early, then accepted a $12/hr fabricator/installer job (Kapaun & Brown) he believed had long-term advancement potential.
Ryan sought administrative modification of child support under Iowa Code chapter 252H; the administrative request was denied and he requested a hearing under chapter 252H.
The district court found Ryan’s income reductions were not motivated by an intent to deprive his children of support, concluded the changes were reasonable and aimed at improving family circumstances and future earning capacity, and modified his child-support obligation.

Issue	Plaintiff's Argument (Amethyst)	Defendant's Argument (Ryan)	Held
Whether a voluntary reduction in income bars modification of child support	Ryan voluntarily reduced earnings; modification should be denied	Changes were made to improve time with children and future earning prospects, not to evade support	Modification appropriate; reduction not motivated by intent to deprive children
Whether changed circumstances are substantial under Iowa law	Continued enforcement of original decree should remain despite income drop	Income change is substantial (exceeds guideline threshold) and justifies modification	Substantial change proven; modification warranted
Whether court may rely on actual earnings vs. earning capacity when reduction is voluntary	Use higher earning capacity, not reduced actual earnings	Use actual current earnings since reduction was reasonable and for family benefit	Court used actual earnings; no substantial injustice shown by that approach
Whether parent’s future earning potential precludes modification now	Future potential shouldn’t excuse present reduction	Job changes intended to improve long-term capacity; present earnings reflect reality	Present earnings appropriate for support calculation given circumstances

In re Marriage of McKenzie, 709 N.W.2d 528 (Iowa 2006) (voluntary income reduction may not automatically bar modification; court may consider earning capacity to avoid injustice)
In re Marriage of Walters, 575 N.W.2d 739 (Iowa 1998) (child support generally not modified for self-inflicted income decreases intended to deprive children)
In re Marriage of Vetternack, 334 N.W.2d 761 (Iowa 1983) (criteria for modifying dissolution decrees based on changed circumstances)
In re Marriage of Duggan, 659 N.W.2d 556 (Iowa 2003) (voluntary retirement without valid reason can justify treating earning capacity as income for support calculations)
In re Marriage of Rierson, 537 N.W.2d 806 (Iowa Ct. App. 1995) (modification decisions depend on unique facts of each case)