Nita Kissel Fanning v. Whitney Ely Fanning
Nita Fanning appealed a court order reducing her former husband, Whitney Fanning's, child-support payments. The trial court had found a reduction in Whitney Fanning's net resources. However, Nita Fanning was improperly denied discovery of essential financial documents, which prevented her from adequately challenging Whitney Fanning's claims regarding his income and net resources. The appellate court ruled that the denial of discovery was a material error that deprived Nita Fanning of her rights and the trial court of sufficient evidence. Consequently, the judgment was reversed, and the cause was remanded for a new trial.