Langley v. Langely (Nebraska 2021)

A correct result in a child support modification will not be set aside even if the court applied the wrong reasoning. In the original divorce decree, neither party was ordered to pay support based on the close to equal parenting schedule. The mother filed to modify custody and the father counterclaimed to modify custody and support. The father alleged his reduced income as a substantial change of circumstances. The trial court granted the modification based on the amount of time the children spent with each parent and ordered the mother to pay support. The mother appealed. The appellate court upheld the decision but on different grounds. It found the parenting time wasn’t a substantial change in circumstances in that the parents were following the plan set out in the decree. However, the father was earning substantially less than before and the support amount met the criteria for a modification.