For five years during his marriage to Renee Pennington, Christopher Pennington worked forty hours a week at a day job and four nights a week at a steakhouse. He hoped to quit the second job once Renee graduated from law school. Eventually the parties divorced and he paid child support. He continued to work the second job to make ends meet. But he was tired.In Pennington v. Pennington, 2011 CA 1022, the First Circuit held that the Family Court ruled correctly when – after Renee graduated – it reduced Christopher’s child support by refusing to consider the money he had made from the second job. The Court found that the second job had always had a limited purpose – to support the family while Renee was in school – and that requiring him to engage in long-term additional employment would be inequitable.