Gordon v. Gordon (Tennessee 2018)

Deviations from presumptive child support must be supported by specific reasons. In this case, the parents agreed to an upward deviation in child support in the initial support order. The deviation was for “the needs of the family, equity of the parties, and best interest of the minor children.” Later, the mother filed a petition to modify residential parenting plan. During the trial, the father testified that he believed the deviation was for child care costs. In the final order, the court ordered the father to pay half of the child care costs and entered a judgment. The father appealed. He argued the upward deviation in child support was meant to cover child support. The appellate court disagreed and found that child care was not given as a specific reason for the deviation.