Carman v. Harris (Kansas 2019)

A parent’s income for child support can be adjusted for specific factors. On appeal, the application of an adjustment is reviewed for an abuse of the court’s discretion. The mother filed to modify child support, among other terms of an initial custody and support order. The district court modified the support based on the parents’ current incomes. The mother appealed the order based on several grounds: adjustments for insurance, parenting time, and multiple family, and retroactive date of the modification. The appellate court upheld the order. It found all the grounds for appeal were discretionary, and the court didn’t abuse its discretion. The mother didn’t provide evidence to support her claims that the father wasn’t paying insurance or exercising his parenting time. The court followed Kansas statute when setting the retroactive date of the order.