In this case, Shane filed a motion to modify his child support obligation based on voluntary underemployment, but the court found insufficient evidence of a change in circumstances. The Court of Appeals upheld a contempt finding against Shane for failing to make payments on a jointly obtained vehicle as specified in the divorce decree, even after a post-decree Chapter 7 bankruptcy discharge. The court clarified that state courts have the power to decide if a specific debt is dischargeable and that non-support divorce debt may not be discharged in bankruptcy. The trial court's award of attorney's fees to Sondra was also affirmed by the Supreme Court of Kentucky.
Howard v. Howard (2011)
Supreme Court of Kentucky
336 S.W.3d 433
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