Standard of Review for Child Support Modification in Texas
Material and Substantial Change Standard
In Texas, a trial court may
modify a previous child support order if
“the circumstances of the child or a person affected by the order have materially and substantially changed” since the date of the order's rendition. Act of May 29, 2005, 79th Leg., R.S., ch. 916, § 19, 2005 Tex. Gen. Laws 3148, 3154 (amended 2007) (current version at
Tex. Fam. Code Ann. § 156.401(a)(1) (Vernon Supp. 2007)). As the movant, Father had the burden to show the requisite material and substantial change in circumstances since the entry of the previous order. Cameron v. Cameron, 158 S.W.3d 680, 682 (Tex. App.-Dallas 2005, pet. denied).