The father filed a motion to terminate child support, claiming the parties' 18 year old son was emancipated. But because the New Jersey divorce judge decided the motion merely based on the parents' conflicting certifications, the case is reversed and remanded for a plenary hearing to determine the extent of the son's disability and whether he has the capability to obtain/maintain gainful employment to contribute toward his own maintenance. Mascuillo v. Mascuillo, New Jersey App. Div., January 28, 2010