Knipper v. Enfinger (Tennessee 2020)

When ordering retroactive support, a trial court can deviate from the presumptive support amount but must make the statutorily required findings to support the deviation. The mother appealed a trial court order that denied her request for support retroactive to the child’s birth. The appellate court reversed the trial court’s order and remanded for additional findings. The appellate court found that the order didn’t contain the required findings which include: the reasons for the deviation, the amount that would be been awarded absent the deviation, the reason why an application of the guidelines would be unjust and how the deviation serves the child’s best interest. The appellate court found the record reflected the deviation was made due to the mother’s bad behavior and that, without more, was not sufficient.