Marriage of Goyal CA2/6

DISCUSSION

Modifying spousal or child support requires proving a material change in circumstances since the prior order. (See In re Marriage of McCann (1996) 41 Cal.App.4th 978, 982 [must show increase or reduction in supporting spouse’s ability to pay for supported spouse’s needs]; In re Marriage of Leonard (2004) 119 Cal.App.4th 546, 556 (Leonard) [supporting parent bears burden to show “changed circumstances warrant a downward adjustment in child support rests with the supporting spouse”].) We review support-related decisions for abuse of discretion. (In re Marriage of Shimkus (2016) 244 Cal.App.4th 1262, 1273 (Shimkus); In re Marriage of Butler & Gill (1997) 53 Cal.App.4th 462, 465.) We conclude the court properly considered the uneven nature of Prem’s employment and compensation.

3 Prem argues his current cash flow, not his history as an independent contractor, should figure most prominently in the court’s analysis of his circumstances. (See In re Marriage of Mosley (2008) 165 Cal.App.4th 1375 (Mosley) [reversing trial court order requiring spouse to borrow money to maintain support levels, assuming he would receive discretionary year-end bonuses in the future].) However,…