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

Robinson v. Robinson (Tennessee 2022)

June 2022

To find a parent voluntarily unemployed, the court must consider the parent’s choices and the reasonableness of the choices considering a parent’s obligation to support the child. The parents filed for divorce. They owned three Subway stores. Pending the final order, the court ordered that the mother would manage the stores and the father was to find another job. The father failed to find a job, so when calculating child support, the trial court imputed income to him that equaled the income for a Subway store manager. The father appealed, arguing the trial court had to first find him voluntarily unemployed before imputing income.

Hollis v. Hollis (Tennessee 2022)

June 2022

The definition of income is broad and all-encompassing. A reasonable necessity standard is applied to child support awards when the parents earn more than $10,000 per month. The parents of two special needs children filed for divorce.  The husband, a financial advisor, was the primary source of income for the family. His income included a loan from his employer, which was tied to performance goals. The loan was forgiven as he met the goals. As his income exceeded $10,000 per month, the trial court had to consider the reasonable necessity standard when awarding support above the guidelines. In its final order, the trial court found support should be set above the guideline amount in light of the father’s income and the children’s extensive special needs. Both parents appealed the final order.

Kelley v. Zitzelberger (Mississippi 2022)

June 2022

To modify a child support order, a parent must show a material change of circumstances that was unforeseen at the time of the original order. The father retired from the military and requested a modification of child support. The parents had orally agreed to reduce support and that the father would pay for certain expenses. The father wanted to offset the expenses with his arrears. The chancery court denied his request and entered a judgment for arrears. The appellate court affirmed.

Fox v. Ozkan (Kansas 2022)

June 2022

The doctrine of acquiescence to a judgment applies when a parent complies with an income withholding order. A judgment for unreimbursed medical expenses was entered against the father. When the judgement was entered, an income withholding order was also put in place. After his motion for reconsideration was denied, he appealed. In the meantime, he satisfied the judgment.

Hehn v. Johnson (Wyoming 2022)

June 2022

Even in default child support hearings, the district court has an obligation to determine income for both parents. The mother filed for paternity and support. The father was served, but failed to answer, and the clerk entered default. Both parents appeared at the hearing. The father was awaiting sentencing on a criminal charge, so a temporary order was entered. Upon the father’s release, the mother requested a default hearing. Both parents appeared. The district court took no evidence. The final order granted mother custody, set out visitation, and ordered child support based on the mother’s calculation. The mother appealed.

Williams v. Wiley (North Carolina 2022)

June 2022

A clerical error will not render a Notice of Registration of Foreign Support Order invalid. The parent claiming improper service must provide evidence of the defect. The Wake County child support office filed a Notice of Registration of Foreign Support Order, which was confirmed. The mother filed to dismiss the confirmation order, arguing the wrong person was served and she didn’t live at the address where the notice was mailed. The trial court denied her motion, and she appealed.

Ensuring Families Receive Child Support Payments

May 2022

The child support program was initially set up to recover benefits paid to families. Even though this mindset has changed, there are still policies in place to reimburse the federal government before child support goes to the family. This brief explores policies for pass through and disregard and distribution that will get money into the hands of the family. Research shows parents who know their support is going to their family are more likely to pay and more willing to establish paternity.

Noncustodial Parents and the GIG Economy

May 2022

Collecting child support from parents who work in the gig economy is difficult, and the number of parents working in the gig economy is increasing. This brief uses Census Bureau information to define the gig workforce and the number of noncustodial parents who are working in the gig economy. 

Centering Child Well-Being in Child Support Policy

May 2022

Child support policies should be designed to maximize child well-being. This brief, part of the Centering Child Well-Being in Child Support Policy series, examines policies to increase the child support that goes to families, remove barriers to payment, increase job retention, support father engagement, and encourage co-parenting.

McLane v. Goodwin-McLane (North Carolina 2022)

May 2022

An artificial insemination contract is valid as long as there is proper consideration. This case involves three people, a sperm donor, the recipient, and the other parent, plaintiff. The Plaintiff and the recipient, a same-sex couple, married and decided to have a child. The donor agreed to donate sperm. After the recipient became pregnant, the donor, the recipient, and the plaintiff, entered into a contract drafted by the donor. The parents separated after the child’s birth. The donor filed a legitimization action. The plaintiff filed a breach of contract action against the donor and the recipient, alleging donor had given up his right to raise the child as part of the contract.