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

Barham v. Barham (North Carolina 2022)

December 2022

A parent can’t unilaterally  modify a child support order. The original divorce decree ordered the father to pay support for the parties’ eight children. Support was modified several times. After entry of the latest modification, the father began paying one cent per pay period toward monthly support. He filed for credit for overpaying support, arguing he had made two additional child support payments each year for the years spanning 2013 -2019. The mother filed a motion for contempt for nonpayment. The trial court found the father in contempt.

Hoard v. Barrom (Tennessee 2022)

December 2022

 A court is without jurisdiction to modify a support order once a child has emancipated. The state of Tennessee petitioned to modify the father’s support order. The child turned 18 the following month. The trial court modified the order. A year later, the father moved to set aside the order, arguing the trial court had no jurisdiction to modify since the child had turned 18 and graduated from high school before order entry. The court denied the motion to set aside. The father appealed. The appellate court vacated the support order.

Marcel v. Marcel (Tennessee 2022)

November 2022

To calculate child support income for a parent with variable income (wages, bonus, overtime), the trial court should consider income over a period of time which will account for the variable income. In this case, the father worked at a plant and his income varied. He earned wages, bonuses, overtime, and double time. To calculate his income for child support, the trial court used his last four paystubs, which didn’t include any of this income. However, the information on the pay stub indicated that this type of income had been received year-to-date. The mother appealed the child support term of the final order.

Voluntary Paternity Affidavit Program 2021 Hospital Survey Analysis

November 2022

With the goal of increasing its paternity establishment performance measure, the state of Iowa conducted a survey to gather information about the hospital-based paternity acknowledgement program and reasons for the rejection of voluntary acknowledgements. This report gathers information on five different areas: the demographics of professionals who assist with voluntary paternity establishment at the hospitals, information about patient education, the materials and resources used during education, potential areas of improvement on the education process; and reports related to rejections of voluntary acknowledgements.

Eidson v. Kakouras (North Carolina 2022)

November 2022

Stipulations to facts are favored but they must be clearly shown in the record and both parties must agree. The parents divorced in 2012 and post-divorce actions for modification of custody and child support began immediately. Specific to this appeal, the father appeals the latest child support order, which resolved a variety of outstanding motions. The appellate court vacated the orders on appeal and remanded.

MDHS v. Reaves (Mississippi 2022)

November 2022

A child support payment vests in the child, and once paid, is not reimbursable. The father was ordered to pay child support in the divorce decree. The father filed to modify custody, and child support was addressed in several orders throughout this proceeding. The final order addressing child support found the father was entitled to reimbursement by the Mississippi Department of Human Services (MDHS) for overpaid support. MDHS appealed.

Associations Between Problematic Substance Use and Child Support Order Compliance

October 2022

Substance abuse is a well-documented barrier to payment of a child support order in that it a parent’s ability to pay and willingness to pay. This study considers the relationship between child support compliance and problematic substance abuse. The researchers found problematic substance abuse affects compliance with child support. It suggests supports for these NCPs including programs to connect NCPs to treatment resources and assistance with modifications.

Taylor v. Taylor (Tennessee 2022)

October 2022

An order must contain findings of fact to support an upward deviation for extraordinary educational expenses. This award is in addition to presumptive support. The parents had two children. The father’s original support order included an upward deviation for private school tuition. The parties filed numerous post-divorce motions. In the latest action, following a bench trial, the trial court modified support. The final order was then amended. The support amount in the amended order differed from the support amount in attached worksheet, and the father was ordered to “pay per pay period.”

Green v. Green (Mississippi 2022)

October 2022

When a parent’s annual adjusted gross income exceeds $100,000, Mississippi statute requires findings as to whether an application of the guidelines is reasonable. The parents, who had two children, filed for divorce. The father’s adjusted gross income exceeded $100,000. To set support, the chancery court followed the Mississippi child support guidelines, which set support for two children at twenty percent of the parent’s adjusted gross income. The mother appealed several terms of the order including the child support calculation. She argued the support amount wasn’t sufficient.

States Should Use New Guidance to Stop Charging Parents for Foster Care, Prioritize Family Reunification

October 2022

The federal Administration for Children & Families recently issued new policy guidance that allows state agencies to stop referring Title IV-E foster care cases for the establishment of a child support order. The old policy had very little benefit. These families are low-income. A support obligation takes money out of an already financially fragile family. Collecting support wasn’t cost-efficient. The new guidance promotes reunification efforts and help the custodial parent maintain the family home.