Welcome to the YoungWilliams Research & Case Law Library.  Use the filters below to select categories of interest to you.  Currently our Library consists of academic and government research articles and reports from around the country, federal opinions, and case law from states in which our full service child support projects are located: Colorado, Kansas, Mississippi, Nebraska, North Carolina, Tennessee, and Wyoming.  Sign up to receive updates by clicking the blue  box at the left of the page.

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Research & Case Law

Van Fleet v. Guyette (Wyoming 2020)

June 2020

A parent can’t disregard a statutory requirement then complain about its outcome. This matter came before the court on a modification of custody. With respect to child support, the court ordered both parents to file a financial affidavit. The mother filed hers along with supporting information. The father didn’t, and the court found him in contempt. The contempt order gave him an additional opportunity to file the affidavit. Otherwise, the mother was directed to file an affidavit of imputed income and allege his income.

People in Interest of S.C.

June 2020

The section of Colorado statute which adopted the Uniform Interstate Family Support Act (UIFSA) gives parties the right to testify by phone. The state of Missouri asked the state of Colorado to establish paternity with respect to the minor child. The father lived in Colorado. The mother had an outstanding warrant for her arrest in Colorado. She declined to appear at the proceeding in person. The magistrate refused to hear telephone testimony and entered an order closing the case. The district court affirmed the order. The child support agency appealed. The appellate court issued an order to show case ordering the child support agency to show the order was a final, appealable order.

Lasu v. Lasu (Nebraska 2020)

June 2020

A documented travel expense may qualify as a deviation from presumptive child support if it is in the child’s best interests. In this divorce case, the court awarded the mother primary physical custody of the child. The mother lived Nebraska, and the father in California. The district court calculated support and deviated from presumptive support for travel expenses. The father appealed the custody determination and argued the travel deviation should have been bigger.

Ivory v. Albert (Mississippi 2020)

June 2020

A child support obligation may be terminated due to a child’s clear and extreme actions. The father filed to end his support obligation to the child. He alleged the child would not see him and didn’t want a relationship with him. The trial court ended the support. The mother appealed. The appellate court reversed the decision, finding the trial court used the right standard but didn’t correctly apply the standard to the facts.

In re Goodpasture (Kansas 2020)

June 2020

The trial court doesn’t necessarily lose jurisdiction to enforce a child support order when one parent moves from the state. The parents divorced, and the divorce decree ordered the father to pay support for their three children. The mother assigned her right to child support to the Kansas Department of Children and Families in 2018. The father moved to set aside the order arguing that the court no longer had personal and subject matter jurisdiction because the mother had moved from Kansas. The trial court denied the motion. The father appealed.

In re Guha (Kansas 2020)

June 2020

The determination of a parent’s income from a subchapter S corporation is fact specific. The court will consider the company’s earnings history, ownership share, and the parent’s control over distribution and retention of the net profits. In this high-income case, the father’s business was organized as a S Corporation. In this modification action, the trial court found his income included his salary, maintenance payments, and 70% of the company’s gross income. The father appealed this determination.

Abraham v. Abraham (Tennessee 2020)

May 2020

A request for an upward deviation for extracurricular activities is discretionary. A parent must support the request with evidence of the expenses. This post-divorce action came before the court on several grounds. Specific to child support, the mother requested an upward deviation in child support for the children’s extracurricular activities. The trial court denied the request, stating that the mother failed to provide proof of the expenses. The mother appealed.

Story Behind the Numbers: Millennials in the Child Support Program

May 2020

Millennials are on the verge of passing the Baby Boomers as the country’s largest adult generation. This report uses data from the Federal Case Registry and Debtor File and survey data from the U.S. Census Bureau and the National Center for Health Statistics to analyze the role of the millennials in the child support program. 

Thompson v. Thompson (Nebraska 2020)

May 2020

To receive credit for health insurance premiums, a parent must provide specific information as to the cost attributable to the child. The father filed to modify custody and support. After hearing, the district court modified child support based on the birth of the father’s first child but didn’t give credit for an unborn child. The court also declined to credit him for health insurance premiums paid prior to the modification. Because the child support worksheet attached to the order didn’t include the cost of the father’s current health insurance premium, the father filed a motion to alter or amend. He offered new evidence of the cost his health insurance premium, but the court denied the motion. The father appealed.

Dixon v. Olmstead (Mississippi 2020)

May 2020

Proof of a substantial change of circumstances isn’t required when a IV-D agency petitions for a modification under the three-year review statute. However, the record must contain evidence of the parent’s income. The father filed to terminate support and his parental rights to a minor child. The Mississippi Department of Human Services (MDHS) filed a cross-complaint to modify support. The father also filed for contempt over visitation issues. Specific to support, the chancellor upwardly modified the support amount. The father appealed.

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