Voecks v. Voecks
In Voecks v. Voecks, 171 Wis. 2d 184, 491 N.W.2d 107 (Ct. App. 1992) the circuit court determined that William Voecks' incarceration demonstrated a substantial change in circumstances sufficient to warrant a reduction in child support. See Voecks, 171 Wis. 2d at 186, 491 N.W.2d at 108.
Cheryl Voecks argued that the circuit court did not have the authority to modify child support because William's reduction in income was a voluntary, self-inflicted change in financial circumstances. See id. at 187, 491 N.W.2d at 109.
The Court stated that we could not conclude, as a matter of law, that incarceration can never be the basis for a reduction in child support. See id. at 188, 491 N.W.2d at 109.
Rather, the Court concluded that "incarceration is a factor that the court may consider when determining whether it should exercise its discretion to modify child support." Id.
After examining the analysis of the circuit court, we upheld its exercise of discretion in reducing child support. See 171 Wis. 2d at 190-91, 491 N.W.2d at 110.