Alexander v. Alexander (Tennessee 2019)

A judgment for child support arrears, which is based on a child support amount different from that shown on the child support worksheet of record, is void. In their divorce, the parents agreed to no child support. In return, the mother was to contribute to a college fund for their children. The trial court adopted the marital dissolution agreement, entered a permanent parenting plan that set out mother’s presumptive obligation, and referenced the required child support worksheet, which showed a deviation to zero. Several years later, in a modification action, the trial court entered a judgment against the mother for past due support based on the presumptive support amount. The mother appealed. The appellate court reversed the decision. It found that Tennessee statute requires a child support worksheet, which then becomes part of the official record. The child support worksheet reflected a zero support order. A judgment entered for a different amount was an abuse of the court’s discretion.