Pearrow v. Pearrow (Nebraska 2019)

The district court has flexibility to craft an appropriate support amount when parents have an unusual custody arrangement. The worksheet must still accompany the order so the appellate court can properly review an order. The parents divorced and agreed to joint physical and legal custody of the children. A year later, the mother filed to modify the decree. The parents agreed that the mother would have primary custody of the two older children, and the parents would have joint custody of the younger two. The court adopted the father’s proposed support calculation. He used a hybrid calculation. He figured support for all four children under each calculator, then averaged the amount and gave credit for providing health insurance. The mother appealed. The court of appeals upheld the child support calculation. It found no merit to the mother’s argument that the district court deviated from the guidelines. Because of the custody arrangement, no one guideline calculation applied. Instead, the court used some flexibility to find a support calculation that best addressed the situation.