Daniels v. Yasa (Kansas 2021)

No. 122,080 (Kan. Ct. App. 2021)
December 2021

The Kansas Department for Children and Families filed to modify a Missouri child support order. The father requested his support obligation be terminated due to his child’s failure to comply with the requirements to receive support after high school. He also requested reimbursement of his support paid from the time of the child’s high school graduation. The district court entered a judgment for medical and educational expenses, denied his request for reimbursement, and he appealed.  The appellate court affirmed in part, reversed in part, vacated, and remanded. The appellate court found the child had failed to strictly comply with the requirements under Missouri law for support after high school graduation. The father’s obligation to support the child ended at his date of graduation. Because the child wasn’t eligible for support after high school, the judgement entered against the father for medical and educational expenses was vacated. Missouri law does allow for a refund of support paid after emancipation. However, the failure to comply with the post-high school support requirement didn’t automatically amount to emancipation. The child emancipated once he was ineligible to enroll in college.