Thompson v. Thompson (Nebraska 2020)

No. A-19-1011 (Neb. Ct. App. 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. The appellate court upheld the district court order. It found that the father hadn’t appealed the original order as to the health insurance provision and wasn’t entitled to a credit as this point. If he had paid the premiums after filing the modification, he might have been entitled to credit. The appellate court also found while the order didn’t factor in the cost of the current premium, the evidence the father provided was submitted following the close of evidence and still didn’t clearly set out the  amount of the premium attributable to the child.