In Eisinger v. Pachacek, http://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=105211, the Wisconsin  Court of Appeals ruled that a change in one parent’s income is not, by itself,  a “substantial change in circumstances” necessary to modify child support.  The Court found that, although the mother’s income had increased by $3,000 per month, neither the father’s (the payer’s) income nor the child’s needs were significantly different from the time of the previous child support order.  Even the receipt of state disability benefits by the mother was not a sufficient change to modify child support.   This case is interesting because it focuses on the child’s needs, as opposed to simply whether a parent’s income has increased.  Perhaps too often, in Wisconsin child support cases, family lawyers and judges just assume a change in circumstances solely based on income.   This case is a good reminder for family lawyers that there  are other changes to consider during child support cases.