Key legal question
Whether the appeal could challenge the cantonal finding that no substantial change of circumstances justified reducing child maintenance under Art. 286(2) CC.
Extracted holding
The appellant failed to show arbitrary fact-finding or a legally relevant change of circumstances; the cantonal court's assessment stood.
Extracted reasoning
The court held that the father had not demonstrated an actual change between January 2003 and September 2005: he was not earning income at either time, and his arguments on the vehicle and his finances were largely appellatory and unsupported. New facts were inadmissible.