Who Pays Child Support: Noncustodial Parents’ Payment Compliance

To better understand patterns of noncustodial parent (NCP) payment compliance, this study builds on what has already been documented about the Maryland public child support caseload and provides a first-ever, systematic look at the question of who pays current support, how much they pay, and how this relates to NCPs’ demographic characteristics, employment patterns, and…

Read More

Imputed Income Among NCPs: Characteristics and Payment Outcomes

This report looks at cases with imputed income using a random sample of public (IV-D) child support cases in the Maryland Caseload. The study examines payment outcomes over a two-year period for cases in which noncustodial parent income appears to be imputed. Then, this information is compared to payment outcomes in cases where actual income…

Read More

Edwards v. Edwards (Kansas 1958)

An order of temporary support, in a divorce action, is merely a temporary provision for a child’s support until the final determination of the divorce action. The order for temporary support does not become a final judgment of support.

Read More

Andler v. Andler (Kansas 1975)

A parent is entitled to credit for Social Security payments by the government against his or her liability for child support under a divorce decree to the extent of, but not exceeding, his or her monthly obligation for child support.

Read More

Brady v. Brady (Kansas 1979)

When a child attains the age of majority, or when a child goes to live with the other parent, or when a child dies, the obligation to pay support for that child should automatically cease and terminate unless an agreement provides otherwise.

Read More

Brady v. Brady (Kansas 1979)

When a child attains the age of majority, or when a child goes to live with the other parent, or when a child dies, the obligation to pay support for that child should automatically cease and terminate unless an agreement provides otherwise.

Read More

Brady v. Brady (Kansas 1979)

When a child attains the age of majority, or when a child goes to live with the other parent, or when a child dies, the obligation to pay support for that child should automatically cease and terminate unless an agreement provides otherwise.

Read More

Mills v. Habluetzel (Federal, US Supreme Court 1982)

The period for ascertaining the fatherhood of the child must be sufficiently long to permit those who have an interest in the child to bring an action on their behalf despite the personal difficulties that may surround the birth of a child outside of wedlock.

Read More

Whisler v. Whisler (Kansas 1984)

Parents cannot legally reduce or terminate a child support obligation by contractual agreement. That right is the child’s and can be reduced or terminated only by court order.

Read More

Rose v. Rose (Federal, US Supreme Court, 1987)

A state court has jurisdiction to hold a disabled veteran in contempt for failing to pay child support, even if the veteran’s only means of satisfying his obligation is to use veteran’s benefits received as compensation for a service connected disability.

Read More

Hicks v. Feiock (US 1988)

If both civil and criminal relief is imposed in the same action, then the criminal feature of the order is dominant and fixes its character a criminal for purposes of review and burdens of proof.

Read More

Clark v. Jeter (Federal, US Supreme Court, 1988)

The period for ascertaining the fatherhood of the child must be sufficiently long to permit those who have an interest in the child to bring an action on their behalf despite the personal difficulties that may surround the birth of a child outside of wedlock.

Read More

In re Marriage of Ross (Kansas 1989)

Prior to ordering a blood test to determine whether the presumed parent is the biological parent, the district court must consider the best interests of the child, including physical, mental, and emotional needs.

Read More

In re Marriage of Ross (Kansas 1989)

Prior to ordering a blood test to determine whether the presumed parent is the biological parent, the district court must consider the best interests of the child, including physical, mental, and emotional needs.

Read More

In re Marriage of Peak (Kansas 1989)

A child support obligation terminates “when a child goes to live with the other parent” is clarified and restricted to situations where a permanent change of residence is involved.

Read More

In re Marriage of Peak (Kansas 1989)

A child support obligation terminates “when a child goes to live with the other parent” is clarified and restricted to situations where a permanent change of residence is involved.

Read More

State ex rel. Secretary of SRS v. Clear (Kansas 1991)

A child’s parent, parents, or guardian shall be liable to repay to the secretary of social and rehabilitation services any assistance expended on the child’s behalf, regardless of the specific program under which the assistance is or has been provided.

Read More

Jensen v. Runft (Kansas 1992)

The Uniform Parentage Act requires courts to act in the best interests of the child when imposing legal obligations or conferring legal rights on the mother/child relationship and the father/child relationship.

Read More

In re Adoption of RSC (Wyoming 1992)

An action to declare nonexistence of a presumptive father and child relationship until almost four years after all relevant facts are know will be time barred – not within a reasonable time.

Read More

Hasty v. Hasty (Wyoming 1992)

A trial court has the authority to deviate from guidelines by considering non-custodial parent’s support obligations to later born minor children of subsequent marriages.

Read More

Dowdy v. Dowdy (Wyoming 1993)

Slight deviations from the guidelines without issuance of the proper findings does not require appellate courts to reverse and remand back to a district court.

Read More

In re Marriage of Walje (Kansas 1994)

Where support is paid directly to custodial parent, rather than through the channels specified in the support order, the non-custodial parent who has not fully complied with the support order and will be found to be in arrearages.

Read More

In re Paternity of SDM (Wyoming 1994)

A child who has not been included as a party in any prior paternity case nor any prior divorce action cannot be foreclosed by the doctrines of res judicata, collateral estoppel, or judicial estoppel with respect to the child’s subsequent effort to achieve determination of paternity.

Read More

Sharpe v. Sharpe (Wyoming 1995)

The denial of visitation rights by either the custodial parent or the child does not constitute a change in circumstances justifying the reduction or termination of the non-custodial parent’s support obligation.

Read More

In re Marriage of Lewallen (Kansas 1995)

For the purposes of the Kansas Child Support Guidelines, a farmer is a self-employed person whose domestic gross income is that person’s gross income less those actual expenditures reasonably necessary for the production of income.

Read More

Florida Dept. of HRS v. Breeden (Kansas 1995)

Where a paternity proceeding is initiated through an interstate support enforcement mechanism and the child resides in another state, the trial court should await a determination from the court of the initiating state that a blood test establishing paternity is in the best interests of the child before making its determination of paternity.

Read More

Rocha v. Rocha (Wyoming 1996)

In a divorce action, a trial court has discretion in concluding that a father’s child support payments can or cannot offset the parties’ original property settlement.

Read More

In re Marriage of Patterson (Kansas 1996)

Although discretionary, the Kansas Child Support Guidelines extrapolation formula must be considered by the trial court when income exceeds the child support schedules. Child support worksheets approved by the court shall be filed in every case where an order of child support is entered.

Read More

In re Marriage of Patterson (Kansas 1996)

Statute gives the trial court the jurisdiction to modify child support and education provisions of minor children, even if they were provided for in a property settlement agreement. Departures from the child support guidelines must be explained by the trial court.

Read More

In re Marriage of Patterson (Kansas 1996)

The extrapolation formula contained in the Kansas Child Support Guidelines for income beyond the child support schedules is discretionary and does not establish a rebuttable presumption as to the level of appropriate support.

Read More

In re Marriage of Jones (Kansas 1996)

When a party neglects to assert a right or claim for an unreasonable and unexplained length of time and the lapse of time and other circumstances cause prejudice to the adverse party, relief is denied on the grounds of laches. The mere passage of time is not enough to invoke laches. The court must consider…

Read More

JA v. CJH (Wyoming 1996)

Where no timely action has been instituted within 5 years of a child’s birth to declare the nonexistence of a father and child relationship, the statutory presumption of paternity becomes absolute, and any action to establish another’s paternity is foreclosed.

Read More

In re Marriage of Johnson (Kansas 1997)

For child support computations, where a parent is paying for family health insurance that covers individuals from more than one family, the cost of the family coverage should be divided among the number of individuals who are covered by the insurance and that number should then be multiplied by the number of children subject to…

Read More

In re Marriage of Johnson (Kansas 1997)

If a reasonable person could conclude that a parent is not deliberately unemployed or underemployed, it is not an abuse of discretion for the district court to refuse to impute the parent’s former income in calculating the child support obligation.

Read More

Blessing v. Freestone (US 1997)

Title IV-D of the Social Security Act requiring that states operate their child support programs in “substantial compliance” with Title IV-D, does not give individuals federal right to force state agency to substantially comply with its provisions. The substantial compliance is merely a guide for Secretary of Health and Human Services to measure system wide…

Read More

Wood v. Wood (Wyoming 1998)

Individual is not voluntarily underemployed because (s)he voluntarily commits a crime, which limits their employment options, if evidence reveals that they make a good faith effort to find the highest paying job possible given their situation.

Read More

In re Marriage of Thurmond (Kansas 1998)

The Kansas Child Support Guidelines are the basis for establishing and reviewing child support orders in the district courts in Kansas. Judges and hearing officers must follow the guidelines. Child support obligations are calculated by completing the Child Support Worksheets.

Read More

In re Marriage of Thurmond (Kansas 1998)

The fact of incarceration, standing alone, is not legal justification for the suspension or modification of the parent’s child support obligation previously determined under the Kansas Child Support Guidelines.

Read More

Rupp v. Grubb (Kansas 1998)

Where a parent is incarcerated in a correctional facility, the fact of incarceration, standing alone, is not legal justification for the suspension or modification of the parent’s child support obligation previously determined under the Kansas Child Support Guidelines.

Read More

Rupp v. Grubb (Kansas 1998)

Where a parent is incarcerated in a correctional facility, the fact of incarceration, standing alone, is not legal justification for the suspension or modification of the parent’s child support obligation previously determined under the Kansas Child Support Guidelines.

Read More

State ex rel. Secretary of SRS v. Miller (Kansas 1998)

When a child is born out of wedlock and no credible evidence exists that the child has a presumed father, the trial court may order genetic testing in a paternity action without first conducting a best interest hearing (Ross hearing), which is to determine whether the testing would be in the best interests of the…

Read More

State ex rel. Secretary of SRS v. Miller (Kansas 1998)

When a child is born out of wedlock and no credible evidence exists that the child has a presumed father, the trial court may order genetic testing in a paternity action without first conducting a best interest hearing (Ross hearing), which is to determine whether the testing would be in the best interests of the…

Read More

State ex rel. Secretary of SRS v. Miller (Kansas 1998)

When a child is born out of wedlock and no credible evidence exists that the child has a presumed father, the trial court may order genetic testing in a paternity action without first conducting a best interest hearing (Ross hearing), which is to determine whether the testing would be in the best interests of the…

Read More

Gentzel v. Williams (Kansas 1998)

Provisions of the Uniform Interstate Family Support Act, the Interstate Income Withholding Act, and the Full Faith and Credit for Child Support Orders Act are applied to the facts of each case.

Read More

TL v. CS (Wyoming 1999)

A presumptive father must provide clear and convincing evidence to meet his burden of proving the results of genetic test favoring another man are inaccurate or somehow deficient.

Read More

In re Paternity of IC (Wyoming 1999)

Where mother voluntarily leaves employment to become a full-time student, a district court can reasonably find she is voluntarily unemployed, and can impute her income from prior years.

Read More

Fleenor v. Fleenor (Wyoming 1999)

The principal portion of a business mortgage payment may be deductible if, in its discretion, the district court determines that the payment reasonably and legitimately reduces net income for child support purposes.

Read More

Ahearn v. Ahearn (Wyoming 1999)

The amount withheld from a father’s pay for deferred compensation is not income under the child support guidelines, because deferred compensation is not a “payment or return in money or in kind” to the father when it is paid into a fund for his later benefit.

Read More