Before addressing the parties' arguments, it is important to define the limits of this case. Moreover, Andrew and Zafa are now emancipated. This case is not about who should have custody of the children or whether they are being adequately supported. Rather, the sole issue is child support arrearages. Thus, we focus solely on the provisions for support in the Vermont and Massachusetts orders, and not on the findings or provisions regarding custody of Andrew.
Wife is correct that Vermont custody orders are modifiable.
Vermont permits modification of a custody order if the petitioning party demonstrates a substantial change in material circumstances from the earlier decree. Wife concludes that Massachusetts did not deny Vermont's order full faith and credit because it was modifiable. Thus, the Vermont custody order was res judicata on the issue of custody and support as the facts existed on November 7, 1977. The Massachusetts court modified the Vermont decree eight months later. In the current action, the trial court found that if there were changed circumstances regarding custody of Andrew, they resulted merely from plaintiff's non-compliance with the Vermont custody order.