Barnett v. Cusimano (Kansas 2002)
Barnett contends the trial court lacked legal authority to increase child support based upon his lack of visitation. This issue requires interpretation of the Kansas Child Support Guidelines. Section V.E.2 of the guidelines permits a reduction of the non-custodial parent's support obligation based upon the amount of time a child is with the non-custodial parent. There is no authority within the guidelines to increase the non-custodial parent's child support obligation through an upward adjustment under the supplemental visitation category based solely upon the non-custodial parent's failure to exercise visitation or spend quality time with a minor child. We conclude the district court erred in providing for a $75 upward visitation adjustment to Barnett's net parental child support obligation.