Jones v. Jones (Nebraska 2020)

A child support worksheet is required regardless of the amount of support. In this appeal of a custody modification, the Nebraska Supreme Court addressed an issue that wasn’t squarely before it. The trial court granted a father’s request to change physical custody of a child and ordered a new support obligation for the mother. A child support worksheet wasn’t attached to the order, which the mother noted in her initial appeal. The appellate court found in favor of the mother, so didn’t reach the lack of a worksheet issue. The father then appealed, and the Supreme Court reversed the appellate court. In the decision, the Court noted the lack of a worksheet. On remand, the Supreme Court directed the Appellate Court to direct the trial court to prepare the appropriate worksheet. The purpose of the worksheet is to allow for meaningful appellate review. The reviewing court court can track how the trial court figured support. This is necessary regardless of the support amount.