Boyd v. Manter, 179 A.3d 906

Manter and Boyd are divorced parents of one minor; primary residence was awarded to Boyd in a 2011 modification and Manter ordered to pay child support.
In Dec. 2015 Manter moved to modify: sought primary residence, decision-making authority, and that Boyd pay support; requested changed contact schedule.
The parties had a long history of poor communication and hostility; frequent transitions in the contact schedule were identified as a major source of stress for both parents and the child.
After a three-day hearing in March 2017, the court preserved Boyd as primary residential parent, reduced transitions in the contact schedule, and adjusted child support to reflect changed incomes.
The court made the child support award retroactive to an unspecified “date of service” and found Manter $10,692.58 in arrears; Manter moved for amended/additional findings which the court denied.
Manter appealed; the appellate court affirmed the contact-schedule modification and denial of additional findings except it vacated the arrears determination and remanded for further findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion in modifying contact schedule	Manter argued the court should have awarded him primary residence and different contact allocation	Court and Boyd argued continuity with Boyd and fewer transitions served child’s best interest	Affirmed — court considered statutory best-interest factors and reasonably reduced transitions to preserve continuity with Boyd
Whether denial of Rule 52(b) motion for amended/additional findings was an abuse of discretion	Manter contended the court failed to make necessary findings to review its decision	Boyd argued the order sufficiently explained the basis for judgment	Denial affirmed in part — court provided adequate findings except as to child-support arrears
Whether court properly determined Manter was $10,692.58 in child support arrears	Manter argued amount unsupported; record lacked interim payment evidence and dates	Court treated award as retroactive to a “date of service” and entered an arrearage figure	Vacated and remanded — appellate court found no findings or record support for the arrearage calculation and ordered further findings/conclusions

Akers v. Akers, 44 A.3d 311 (Me. 2012) (trial court given broad discretion in custody modifications; review for abuse of discretion)
Ehret v. Ehret, 135 A.3d 101 (Me. 2016) (cannot infer findings from record when Rule 52(b) motion denied)
Dalton v. Dalton, 99 A.3d 723 (Me. 2014) (review of denial of motion for findings is abuse-of-discretion)
Bell v. Bell, 697 A.2d 835 (Me. 1997) (primary function of Rule 52 findings is to state basis for judgment for appellate review)
In re A.M., 55 A.3d 463 (Me. 2012) (clear error standard and requirement that factual findings be supported by competent evidence)
Mitchell v. Kieliszek, 900 A.2d 719 (Me. 2006) (harmless-error standard)