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

Johnson v. Johnson (Nebraska 2021)

September 2021

For child support to be properly before the court, the pleading must contain the right language. The original divorce decree granted the parents shared custody of their two children and set child support at zero. The father filed to modify custody and support and the mother counterclaimed for a modification of custody and support consistent with the Nebraska guidelines. The final order found neither party met the burden to change custody. The mother filed to alter or amend the order requesting the court address a material change of circumstances with respect to support. Following a hearing, the trial court entered an order for father to pay the mother. The father appealed.

Sallae v. Omar (Nebraska 2021)

September 2021

A parent who seeks to modify a child support order must show a ten percent change in support, upward or downward, due to financial circumstances which have lasted three months and that will most likely continue for another six months. In this case, the initial support order required the father to pay monthly child support of $50. The mother filed to modify support citing the parties change in employment and income. Testimony showed the father had worked but was not working at the time of hearing. He testified he could only work 20 hours per week, and he suffered from sleeping issues and other ailments. He offered no supporting documentation. The mother was eligible for a raise, which meant the child no longer qualified for Medicaid. She was going to have to insure him through her employer-provided insurance.

Abney v. Pace (Tennessee 2021)

August 2021

If a parent provides  health insurance for a child on top of the court-ordered insurance, the cost must be a reasonable for the parent to receive credit for the premium. In the parent’s divorce decree, the father was ordered to pay support and provide health insurance. The father filed to modify support. The mother answered claiming the father had not provided her with proof of the insurance and she counterclaimed for contempt for failure to pay support.

O’Roake v. State of Wyoming, ex rel. Dept’ Family Svcs. (Wyoming 2021)

August 2021

Child support can continue beyond the age of majority if a child is mentally or physically disabled and incapable of self-support. The Department of Family Services filed extend support for a child beyond the age of the child’s majority due to the child’s diagnosis of a metabolic disorder. The court commissioner recommended modifying support, and the district approved the recommendation. The order continued support so long as the child was enrolled as a full-time college student. The father appealed.

Chalmers v. Burrough (Kansas 2021)

August 2021

A parent’s failure to comply with the registration procedure for UIFSA doesn’t deprive a district court of general subject matter jurisdiction over support orders. The father filed to register and modify a Florida support order in Kansas but failed to attach a copy of the original order, as required by statute. The court temporarily modified support. The mother filed to dismiss the action based on the father’s failure to comply with the registration procedure, arguing the court was without jurisdiction over the order.

Stephens v. Stephens (Mississippi 2021)

August 2021

To modify a child support order, there must be a substantial and material change not anticipated at the time of the original order. To contest a contempt finding, the parent must show evidence of the inability to pay. The parents in this case divorced and the final decree reflected their agreement as to child support and uncovered medical expenses. The mother subsequently filed numerous petitions for contempt. This appeal consolidates the father’s appeal of the two latest orders.

Friday v. Miss. Dep’t of Human Services (Mississippi 2021)

August 2021

A paternity action must be brought before a child turns 21. The Mississippi Department of Human Services filed to establish paternity for a child who at the time of filing was 20 years old. The father filed several motions to dismiss, arguing the child had turned 21 and the case shouldn’t proceed. The Chancery Court entered an order adjudicating the father’s paternity and ordering a year of support. The father appealed.

Canzoneri v. Burns (Tennessee 2021)

August 2021

The Tennessee child support guidelines contain specific factors to consider when declaring parent underemployed. In this modification action, the father was a self-employed landscaper. Citing his education, background, and a booming economy, the trial court found him underemployed and imputed a higher income. Interestingly, his support was reduced because mother’s income had increased. Regardless, the father appealed.

Parental Debt and Child Well-Being: What Type of Debt Matters for Child Outcomes?

August 2021

Child support arrears may have a negative impact on child well-being. In this study, the authors considered different types of debt owed by parents and the impact of debt on their children. Child support arrears are often a large amount of the debt owed by parent. Arrears have been shown to have negative consequences on those who owe them such as poor mental health, high stress, and lack of employability.

Pace v. Pace (Mississippi 2021)

July 2021

If a parent’s earnings are reduced through the parent’s own actions, the court may use earning capacity to determine income for child support. The parents filed for divorce. The father, a doctor, had a substance abuse problem. To keep his medical license, he had to undergo treatment and consent to monitoring. Instead, he surrendered his medical license. During the trial, he claimed he couldn’t afford the monitoring program. The chancellor used his earning capacity to set child support in the final order. The father appealed.