Matthew Brent Ford v. Alyssa Anne Johansen, 1125162

Ford and Johansen divorced in 2014; the final decree (based on a 2013 agreement) ordered Ford to pay $3,250/month child support — the decree contains no guideline calculation or deviation findings.
In 2016 Ford sought a downward modification; the juvenile court reduced support to $1,344 under the guidelines, and Johansen appealed to circuit court.
At the June 2016 circuit-court hearing Johansen testified about her business income (net taxable income: $2,798 in 2014, $18,189 in 2015; profit in early 2016 > $25,000 but uncertain whether that would become personal income).
Ford testified his business had declining gross receipts from 2014 to 2015, but his reported income from the business was higher in 2014 and 2015 than in 2013 ($32,361 in 2013; $54,245 in 2014; $55,011 in 2015).
The circuit court found Ford failed to prove a material change in circumstance and denied modification, reinstating the $3,250 monthly obligation. Ford appealed, challenging evidentiary rulings, alleged income changes, and effect of 2014 guideline amendments; he also requested appellate attorney’s fees.

Issue	Ford's Argument	Johansen's Argument	Held
Whether circuit court erred by barring inquiry into Johansen’s 2013 income (baseline)	Court improperly prevented evidence of Johansen’s pre-decree income, frustrating Ford’s ability to show a material change	Objection was proper; limited questioning did not prejudice Ford	Court erred in sustaining relevance objection but Ford failed to proffer the excluded testimony, so no reversible prejudice; ruling affirmed
Whether increase in Johansen’s income since 2013 is a material change	Johansen’s increased earnings (2014–2016) justify reopening support	Record lacks baseline 2013 income; increases from 2014–15 alone don't show change from 2013	No material change shown because baseline (2013) was not established; affirmed
Whether decrease in Ford’s income is a material change	Ford’s reduced business gross receipts justify downward modification	Tax returns show Ford’s income actually increased from 2013 to 2015	No decrease in Ford’s reported income; no material change; affirmed
Whether 2014 amendments to the child support guidelines allow revisiting award without material change	2014 guideline amendments create an exception permitting review	Any legislative change must be substantive and shown to significantly alter guideline outcome; Ford offered no such proof	Court did not err; Ford presented no evidence the 2014 amendments would significantly change his guideline amount; affirmed

Hiner v. Hadeed, 15 Va. App. 575 (Va. Ct. App.) (modification under Code § 20-108 requires a material change in circumstances)
Milligan v. Milligan, 12 Va. App. 982 (Va. Ct. App.) (initial adoption of guidelines warranted review of pre-guideline awards)
Slonka v. Pennline, 17 Va. App. 662 (Va. Ct. App.) (substantive guideline amendments that significantly change amounts can justify revisiting prior awards)
Ray v. Commonwealth, 55 Va. App. 647 (Va. Ct. App.) (when testimony is rejected before delivery, a proper proffer is required for appellate review)
Molina v. Commonwealth, 47 Va. App. 338 (Va. Ct. App.) (proffer must show admissibility and prejudice)
O’Loughlin v. O’Loughlin, 23 Va. App. 690 (Va. Ct. App.) (standard for awarding appellate attorney’s fees)