Antwayne Eric Ford v. Rita Castillo, 98 A.3d 962

Ford and Castillo divorced in 2004; their pro se separation agreement (incorporated into the divorce decree) allocated custody and required Ford to pay the child’s private school tuition, health insurance, and share other child-related costs.
In 2011 the child lived with Castillo during the school year and Castillo filed for child support under the D.C. Child Support Guideline; incomes had risen (Ford ≈ $237,920; Castillo ≈ $90,000).
The trial court refused to deduct Ford’s court-ordered payments (tuition, insurance, shared medical and school costs, travel, clothing/holiday contributions) from his gross income when computing Adjusted Gross Income (AGI) under the Guideline, treating them as separate obligations from child support.
Using the Guideline without those deductions, the court set Ford’s minimum monthly support at $1,446 and awarded $14,460 in retroactive support for the petition period.
On appeal Ford argued the court should have subtracted those court-ordered child-related expenses as “prior child support orders” when calculating AGI; the Court of Appeals agreed and reversed and remanded for recalculation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court-ordered child-related payments incorporated in the divorce decree must be deducted from a parent’s gross income as “prior child support orders” when computing AGI under the Guideline	Ford: those payments are court-ordered support obligations and must be deducted from gross income before computing Guideline support	Trial court/Castillo: the separation agreement treats tuition and related items as discrete obligations separate from child support, so they need not be credited in AGI	Court: Such incorporated court-ordered child-related expenses qualify as “support orders” and must be deducted from gross income; remand to recalculate AGI and minimum support (court can exercise discretion up to higher amounts)
Whether the trial court erred in modifying the existing child support arrangement at all	Ford (argued on appeal): challenged modification? (court notes Ford clarified he did not seek to change his obligations)	Trial court/Castillo: there was a substantial and material change in circumstances (custody/time with mother and Ford’s increased income) warranting modification	Court: Modification was proper; facts showed substantial and material change sufficient under D.C. Code § 46-204(a)

Araya v. Keleta, 65 A.3d 40 (D.C. 2013) (standard of review for child support/alimony discretion)
Wilkins v. Ferguson, 928 A.2d 655 (D.C. 2007) (reviewing statutory interpretation de novo)
Bailey v. United States, 516 U.S. 137 (U.S. 1995) (statutory interpretation principles — consider placement and purpose)
Brown v. Dyer, 489 A.2d 1081 (D.C. 1985) (treating an incorporated agreement to pay private school tuition as an action for child support)
Carr v. Haynes, 374 A.2d 868 (D.C. 1977) (construing private school tuition obligations as child support)
Cass v. District of Columbia, 829 A.3d 480 (D.C. 2003) (statutory interpretation to give effect to the statute as a whole)
Mazza v. Hollis, 947 A.3d 1177 (D.C. 2008) (discussing merged agreements adopted as court orders)
Duffy v. Duffy, 881 A.3d 630 (D.C. 2005) (effect of merging settlement agreements into court orders)