does not provide a present benefit to the child, but “adds to an accumulating burden which falls upon the parent when he is least able to bear it.”). 3. One-Factor-to-Consider Rule Some jurisdictions hold that an obligor’s incarceration is only one factor to consider in determining whether to modify child support. These cases generally require that the determination be made on a case-by-case basis, considering such additional factors as whether the obligor has other assets or income; the obligor’s past and future ability to earn income; the length of the obligor’s incarceration; and the applicable public policies, such as the best interest of the child, the unclean hands doctrine, and the nature of the crime. See, e.g., Thomasson v. Johnson, 120 N.M. 512, 903 P.2d 254, 257-58 (1995) (<HOLDING>); Oberg v. Oberg, 869 S.W.2d 235, 238
holding that a judgment for attorneys fees may be rendered in the nature of child support regardless of whether the underlying action is one of enforcement or modification holding department had shown abandonment on the basis of factors other than incarceration holding that the trial court abused its discretion in failing to award the increased child support retroactive to the date of the petition for modification because the childs increased need for support and the former husbands ability to pay the increased child support existed at the time the former wifes petition for modification was filed holding that only relevant factors must be considered holding that while incarceration alone is not a sufficient basis for child support modification the foregoing factors should be considered in making the determination