in light of the public policy interest of protecting the best interest of the child); Knights v. Knights, 71 N.Y.2d 865, 527 N.Y.S.2d 748, 749, 522 N.E.2d 1045 (1988) (finding that obligor’s financial hardship resulted solely from his wrongful conduct); Ohler v. Ohler, 220 Neb. 272, 369 N.W.2d 615, 618 (1985) (finding that incarceration is foreseeable result of criminal activity); Noddin v. Noddin, 123 N.H. 73, 455 A.2d 1051, 1053 (1983) (stating that equitable relief will be denied to one who comes to the court with unclean hands). 2. Complete-Justification Rule The jurisdictions that adopt the complete-justification rule follow several lines of reasoning. Some look to the obligor’s intent in committing the crime. See, e.g., Willis v. Willis, 314 Or. 566, 840 P.2d 697, 699 (1992) (<HOLDING>). Still other jurisdictions hold that an
holding that as with a promissory note when the final payment was made on a support judgment the obligation was discharged and after that date husband had no obligation that could support a modification holding that the trial court was without authority to modify a spousal support obligation when the modification proceeding was initiated ten years after the obligation to pay spousal support under the dissolution judgment had been terminated by order holding that evidence the defendant knew the victim supported a finding that the murder was committed to avoid arrest holding that modification will be considered if the obligors criminal act was not committed primarily to avoid the support obligation holding that an issue not presented to the trial court will not be considered on appeal