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

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. 

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.

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.

Williamson v. Williamson (Mississippi 2020)

May 2020

Chancellors have discretion on the determination of adjusted gross income (AGI) for child support. As long as there is no abuse of that discretion, the child support determination will not be overturned on appeal. The father appealed the final divorce order arguing the chancery court improperly calculated his AGI. The court of appeals upheld the child support calculation, finding no abuse of discretion. 

Child Support Enforcement-Led Employment Services for Noncustodial Parents

May 2020

This report examines the issues relative to providing employment services for noncustodial parents (NCP) through the child support program (CSE). The report acknowledges the link between employed NCPs and the ability of the CSE program to income withhold, the most effective tool for collecting child support payments.

In re Ray (Kansas 2020)

May 2020

The right to appeal is statutory, and without a basis for the appeal, it will be dismissed for lack of jurisdiction. The mother and father filed for divorce. A temporary order set child support. Various proceedings ensued around custody for the child. The mother filed to modify the temporary support order, which was denied, and requested permission to move with the child.

Young v. Air Masters Mechanical Inc, (Mississippi 2020)

April 2020

If a parent’s rights to a child have been terminated, that child is not considered a dependent under the Workers’ Compensation Act. The decedent died in the course of his work. He left no survivors. The mother petitioned the Commission to pay child support arrears from the decedent’s workers’ compensation death benefits. The decedent was the biological father of her children but had relinquished his parental rights. At the time of the relinquishment, he owed back support, and the mother had a judgment for the amount. The case made its way to the Supreme Court, where the Court found that the children no longer met the definition of a dependent.

Jones v. Jones (Nebraska 2020)

April 2020

A child support worksheet is required regardless of the amount of support. In this appeal of a custody modification, the Nebraska Supreme Court addressed an issue that wasn’t squarely before it. The trial court granted a father’s request to change physical custody of a child and ordered a new support obligation for the mother. A child support worksheet wasn’t attached to the order, which the mother noted in her initial appeal. The appellate court found in favor of the mother, so didn’t reach the lack of a worksheet issue. The father then appealed, and the Supreme Court reversed the appellate court.

Kimzey v. Kimzey (Wyoming 2020)

April 2020

To modify a stipulated child support order, there must be a substantial change of circumstances in addition to the required change in the support amount. The parents divorced and in the decree stipulated to a child support amount lower than the guideline amount. Following the mother’s move to Arizona, the father filed to modify custody and support. The district court found that mother’s move was a material change of circumstances but found it didn’t warrant a change in custody. The district upwardly modified the father’s support obligation based on a change in the amount of support. The father appealed.

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