Fireoved v. Fireoved (Kansas 2019)

No. 120,893 (Kan. Ct. App. 2019)
October 2019

The application of the multi-family credit is discretionary. When calculating support, the costs of the child’s health insurance and reasonable costs of child care are added to the gross child support obligation. The district court has discretion to determine the reasonableness. The mother had primary residential custody of the parties’ child. She notified the father she intended to move to another city, and the father filed for custody. The trial court granted his petition and ordered the mother to pay support. The mother appealed. On appeal, she argued the court should have applied the multi-family credit because she supported her new husband’s child and that the father didn’t provide sufficient proof of his health insurance and child care expenses. The court of appeals found that application of the multi-family credit was discretionary. The mother didn’t ask for it during the trial, and the court was under no obligation to apply it automatically. The court also found that while it might not have been clear how the father calculated the amount he spent for insurance and child care, the mother didn’t object to his worksheet during the trial and failed to rebut the presumption of reasonableness.