Davis v. Henderson (Mississippi 2021)

When reviewing a lower court’s decision to terminate child support due to the child’s extreme actions, the proper standard of review of abuse of discretion. The chancery court terminated a father’s obligation to support his child based on the child’s refusal to have contact with the father. The obligation was terminated until the child resumed visitation with the father. The court of appeals reversed, finding the father at fault for the deterioration of the relationship. The Supreme Court reversed, finding the appellate court didn’t apply the right standard of review.  In child support actions, the findings of a chancellor should be given deference absent an abuse of discretion. In its limited review, the court of appeals must determine if the outcome was possible in light of the evidence. This recognizes the chancellor’s position as the person who actually viewed the witnesses. The appellate court abused its discretion when it determined the father to be at fault for the lack of a relationship between him and his son. That determination was beyond the scope of review.