March 2017 | No. M2016-01484-COA-R3-JV (Tenn. Ct. App. 2017)

In re: Jalen O-H (Tennessee 2017)

A court can order retroactive support in different amounts for different periods of time as long as evidence supports the determination. The parents in this case had multiple custody arrangements since the child’s birth. The court reviewed the terms of each custody agreement and the time it was in place, the parents’ incomes during that time, and set support accordingly. This amounted to four different support amounts for four separate time periods. The father argued the trial court arbitrarily set the time period but the appellate court disagreed. The appellate court acknowledged there might have been a simpler way to set retroactive support but found the trial court supported its decision with evidence and was reasonable.

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