Williamson v. Williamson (Mississippi 2020)

Chancellors have discretion on the determination of adjusted gross income (AGI) for child support. As long as there is no abuse of that discretion, the child support determination will not be overturned on appeal. The father appealed the final divorce order arguing the chancery court improperly calculated his AGI. The court of appeals upheld the child support calculation, finding no abuse of discretion. The father argued that the chancery court should have averaged his fluctuating income instead of using his 2018 year-to-date earnings. The appellate court found that while the court could have averaged the father’s income, it wasn’t outside its discretion to use the year-to-date earnings. The appellate court also found the lower court properly included overtime and 401(k) contributions to reach the father’s AGI.