Boyd v. Crocker
2016 Ark. App. 382
Ark. Ct. App.2016Background
- Jason Boyd and Candace Crocker had a child (G.B.); Crocker petitioned to establish paternity. Boyd admitted paternity and agreed to temporary child support.
- The circuit court entered agreed temporary orders setting temporary visitation and $400/month support, reserved final custody and support for a hearing.
- At the final hearing, the court received evidence on Boyd’s income, bank records, and tax returns; Crocker later submitted a posttrial brief proposing findings that imputed Boyd’s income at $11,105/month and recommended $1,606/month support.
- The circuit court intended Crocker to submit proposed findings of fact but instead received a brief; the court nonetheless drafted a letter opinion assessing income and directed Crocker to prepare an order reflecting the court’s rulings.
- The court entered an order imputing Boyd’s income at $11,105/month and awarding $1,606/month child support; Boyd appealed the court’s application of the net-worth method for a self-employed payor.
- The appellate court found the record incomplete: a page (page 80 of the letter opinion) was missing from the transcript, and that missing material was material to review of the court’s net-worth analysis; it ordered the record and addendum supplemented and remanded for settlement of the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court properly applied the net-worth method to impute income to a self-employed payor | Boyd argues the court erred in applying the net-worth method (overstated income) | Crocker argues the evidence (bank records, tax returns) supports imputing income using the net-worth method | Not decided on the merits — appeal remanded because the court record is incomplete and must be supplemented |
| Whether the appellate record is sufficient for review | Boyd asserts appellate review should proceed on existing record | Crocker did not successfully contest supplementation request | Court ordered the record and addendum supplemented under Ark. R. App. P.–Civ. 6(e) and remanded for settlement of the record |
Key Cases Cited
(No officially reported appellate or Supreme Court authorities with reporter citations were relied upon in the opinion.)