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Appeals Court Hears Arguments in Danforth v. Smith Over Child Support Modification

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Summary

At a Jan. 29, 2025 sitting of the Massachusetts Appeals Court, attorneys debated whether the trial judge properly found no change in circumstances supporting a child-support modification; the court took the case under advisement.

BOSTON — The Massachusetts Appeals Court on Jan. 29 heard oral argument in Danforth v. Smith (Docket No. 24P439), a dispute over whether a trial judge erred by refusing to modify a prior child-support finding.

Attorney Michael Traft, representing Jonathan Danforth, told the three-justice panel that the trial judge failed to base her modification analysis on the facts the court is required to consider. “This case is basically about a modification of child support and how the trial judge is supposed to apply it,” Traft said, arguing the judge improperly relied on skepticism of the father’s statements rather than the income finding the trial court had previously made.

The panel — Justice Eric Nyman (presiding), Justice Joseph Ditkoff and Justice Chauncey Wood — pressed both sides on evidentiary specifics. Justice Ditkoff noted a May 2019 finding that the father’s income was $38,100 a…

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