ORNELLA RODOLICO VS. TOTOWA BOARD OF EDUCATION,WASHINGTON PARK SCHOOL(L-542-14, PASSAIC COUNTY AND STATEWIDE), A-4140-15T1

Defendant W.L., a 74-year-old sole‑proprietor psychologist, was ordered to pay $331/week in child support for his permanently disabled 50‑year‑old son and 80% of unreimbursed medical expenses.
In 2006 the parties stipulated (after plenary hearing) that defendant’s income was $150,000.
By 2013–2014 defendant claimed income decline (due to managed care) and reported $37,169 on his current Case Information Statement (CIS); his 2014 business return showed large business expenses and his wife earned about $78,000.
Defendant moved in April 2015 to reduce or terminate support, alleging substantial changed circumstances but failed to attach his 2006 CIS or transcript of the 2006 testimony or other prior financial documentation.
The Family Part denied relief, finding defendant did not make a prima facie showing of changed circumstances and noting his ability as a self‑employed obligor to understate income.
Appellate Division affirmed, endorsing the trial judge’s gatekeeping rejection and leaving open that defendant may reapply with proper documentation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant showed a substantial change in circumstances to modify child support	D.L. argued defendant failed to prove changed circumstances and did not provide required prior financial records	W.L. argued managed care permanently reduced his income from ~$150,000 to ~$36,000, warranting reduction/termination	Denied — defendant did not meet prima facie burden; insufficient comparative documentation
Whether defendant’s self‑employment requires expanded scrutiny of reported income	Implicit: court should scrutinize self‑employed obligor’s reporting	W.L. implicitly contended reported CIS income reflects his true income	Held — self‑employed obligor’s income viewed more expansively; court found business deductions and benefits reduced transparency
Whether plaintiff needed to supply financials before trial judge found changed circumstances	Plaintiff argued she need not provide financials until defendant meets burden	Defendant implied both should exchange documents	Held — plaintiff was not required to provide financial documentation until defendant demonstrates changed circumstances
Whether the denial was an abuse of discretion	Plaintiff argued decision was proper	Defendant argued the judge erred in denying relief	Held — affirmed; appellate review finds no abuse of discretion and decision reasonable

Larbig v. Larbig, 384 N.J. Super. 17 (App. Div. 2006) (self‑employed obligor’s income should be viewed expansively)
Donnelly v. Donnelly, 405 N.J. Super. 117 (App. Div. 2009) (burden on movant to prove changed circumstances before discovery from opposing party is required)
Lepis v. Lepis, 83 N.J. 139 (1980) (standards for modification of support and burdens)
J.B. v. W.B., 215 N.J. 305 (2013) (appellate standard: review for abuse of discretion in support modification)
Jacoby v. Jacoby, 427 N.J. Super. 109 (App. Div. 2012) (family‑part decisions not to be disturbed absent manifest unreasonableness)