Vandenbook v. Vandenbrook (Mississippi 2019)

If a parent’s adjusted gross income exceeds $100,000, the court must make findings to support applying the guidelines. The father appealed the award of child support in the final divorce decree. The father earned more than $100,000 annually through a combination of salary, bonuses, and the exercise of stock options. To determine his adjusted gross income for child support, the chancellor averaged his income over four years and then applied the guideline percentage. The father argued the chancellor should have used his base monthly income to set child support, then awarded an additional amount based on any income above the base amount. The court of appeals found that the chancellor failed to make findings as to whether an application of the guidelines as reasonable and remanded the case. The father also appealed the award of retroactive support. The court of appeals found that the amount of retroactive support would be reviewed along with the amount of current.