Mannella v. Mannella
The Sixth DCA affirmed the denial of a former husband's petition to reduce agreed-upon child support, finding competent substantial evidence that his own income had increased and that he had voluntarily restructured his employment to obtain a support reduction. In doing so, the court held that the judicially created 'heavier burden' standard for modifying support set by settlement agreement was superseded by section 61.14(7), Florida Statutes (1993), and that the Florida Supreme Court's contrary language in Overbey v. Overbey was mere obiter dictum with no precedential force. The court certified conflict with the Second, Third, and Fourth DCAs.
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