1

Substantial Change in Circumstance is Required

To establish a substantial change in circumstances, the petitioner must show an increase in the noncustodial parent's ability to pay and an increase in the needs of the child, since the court's previous order. In re Marriage of Schmerold, 88 Ill.App.3d 348 (1980)

2

Presumptions Favor the Best Interests of the Child

Courts may presume that the needs of children increase as they age. In re Marriage of Pylawka, 277 Ill.App.3d 728. It is presumed the cost of living rises. Id. 661 N.E.2d 505 (1996). Courts may presume those needs of the subject children increase as they grow older and as the cost of living rises. In Re Marriage of Pylawka, 277 Ill.App.3d 728, 214 Ill.Dec. 651, 661 N.E.2d 505 (1996).

3

Trial Court Has Final Say

A trial court's decision concerning modification of child support will not be disturbed absent an abuse of discretion. In re Marriage of Sassano, 337 Ill.App.3d 186, 271 Ill.Dec. 864, 785 N.E.2d 1058 (2003).