Resources
Child Support Resource Library
Welcome to the YoungWilliams Child Support Resource Library. Search by keywords or use the filters to select categories of interest to you. Currently, our Library consists of academic and government research articles and reports from around the country, federal opinions, and case law from states in which our full service child support projects are located.
2014 OCSE Annual Report to Congress (Part 2 of 3)
The 2014 OCSE Annual Report to Congress highlights financial and statistical child support achievements based on data reported by state and tribal child support agencies. The content of the Annual Report is mandated by section 452(a) under Title IV-D of the Social Security Act to give Congressional members information that relates to the overall operations and success of the national child support program. Because of its size, this report is divided into three parts. Part 2 of 3 includes state performance from Massachusetts to Wyoming.
2014 OCSE Annual Report to Congress (Part 1 of 3)
The 2014 OCSE Annual Report to Congress highlights financial and statistical child support achievements based on data reported by state and tribal child support agencies. The content of the Annual Report is mandated by section 452(a) under Title IV-D of the Social Security Act to give Congressional members information that relates to the overall operations and success of the national child support program. Because of its size, this report is divided into three parts. Part 1 of 3 includes the narrative, national performance, and state performance from Alabama to Maryland.
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Brown v. Brown (Tennessee 2016)
In order to find a parent in criminal contempt of court for failure to pay child support, a petitioner must prove beyond a reasonable doubt that the parent had the ability to pay the support when it was due and that the failure to pay support was willful. In this case, the Court found that the father had an income sufficient to pay the support and that he willfully chose not to pay because he was unhappy with his obligation.
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Preliminary Report 2015
The FY 2015 Preliminary Report provides data reported by all state child support programs to the federal Office of Child Support Enforcement and includes information on collections, expenditures, paternities, orders established, and other program statistics. This report does not contain data from tribal child support programs. Tribal data will be reported in the FY 2015 Annual Report to Congress.
The Young Fathers’ Employment Program in Maryland: An Initial Review of Participant Outcomes
The Maryland Child Support Enforcement Administration (CSEA) recently funded a three-county noncustodial parent employment program called the Young Fathers’ Employment Program. The participating counties were Baltimore, Caroline, and Talbot. The University of Maryland School of Social Work conducted an initial review or a pre-post assessment of participants’ employment, earnings, and child support payments. The researchers examined the status of each indicator before participants enrolled in the employment program, and then examined changes that occurred in the subsequent year. The sample for this report includes 328 noncustodial parents who enrolled in the program between July 2011 and June 2014, each having one year of pre-enrollment data and one year of post-enrollment data.
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Zupan v. Zupan (Wyoming 2016)
The parent who petitions to modify a stipulated child support order must show a material change in circumstances as well as a 20 percent change in the support amount. This rule addresses the issue of a parent agreeing to a support amount 20 percent lower or higher than the presumptive amount only to petition for a modification as soon as possible based solely on a 20 percent change in the support amount. In this case, the mother alleged a change in custody which satisfied the change in circumstances requirement.
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Smith v. Williams (Mississippi 2016)
A parent who requests reimbursement for birth and other child-related expenses incurred prior to the establishment of a support order must provide proof of the expenses, and the proof must be admitted into evidence. The mother in this case did not provide sufficient proof of her expenses, and the court did not order reimbursement.
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Marshall v. Marshall (Nebraska 2016)
*This case has been reversed and remanded for entry of the decree of the district court, see Marshall v. Marshall, 298 Neb. 1 (2017).
The amount of a parent’s monthly income must be based on evidence and reasonable. When parties have competing amounts for one parent’s income, the court may not determine income by splitting the difference between the two figures. In this case, the appellate court determined the mother’s figure for father’s income was unreasonable and not supported by evidence. The appellate court recalculated the father’s income using the father’s salary, income reported on his tax return, and in-kind income from his family business, which included rent, health insurance, and a cell phone allowance.
Stack v. Stack (Tennessee 2016)
A Tennessee court may modify another state’s child support order when the order has been registered in Tennessee, the court has personal jurisdiction over the parties, and the parties have provided the issuing state with written consent to Tennessee’s ongoing jurisdiction. In this case, the parties filed a Notice of Filing of Agreed Order with the issuing court in Montana, and the Tennessee judge found this filing met the consent requirement even though the order was not a certified copy. The father testified to the authenticity of the order filed in Montana making it admissible as evidence of consent to Tennessee’s ongoing jurisdiction.
Patrick v. Patrick (Oklahoma 2016)
Child support may only be awarded for an adult disabled child if there is a causal relationship between the disability and the child’s inability to support him or herself. In this case, the mother could not be ordered to support an adult child who had entered treatment for drug and alcohol abuse. Assuming that substance abuse met the statutory definition of a disability, no evidence demonstrated he could not support himself when not in treatment.
