130 A.3d 394
Me.2016Background
- Parents (Dumas and Milotte) litigated parental rights and child support after a 2012 child’s birth; bench hearing held April 2015 in York District Court.
- Evidence at hearing focused on two incomes (Dumas: self-employed farrier; Milotte: medical marijuana cultivator) and childcare costs — all key inputs to statutory child support calculation.
- Court set Dumas’s annual income at $30,000 and Milotte’s at $25,000, and used a weekly childcare figure of $215 (equivalent to five daycare days) on the child support worksheet, but provided no explanatory findings.
- Court ordered weekly child support of $173.25; Milotte timely moved for findings and conclusions under M.R. Civ. P. 52(a), seeking explanation for the income and childcare determinations; the court denied the motion.
- The Supreme Judicial Court held the denial was erroneous because Rule 52(a) requires sufficient findings to explain the court’s reasoning and enable appellate review, vacated the child support portion of the judgment, and remanded for findings and conclusions.
Issues
| Issue | Plaintiff's Argument (Dumas) | Defendant's Argument (Milotte) | Held |
|---|---|---|---|
| Whether the district court was required to issue findings of fact and conclusions of law under M.R. Civ. P. 52(a) for child support inputs | Findings unnecessary because judgment and worksheet were sufficient; Dumas also argued she was not underemployed due to childcare for a child under 3 | Findings required to explain how court reached income and childcare figures used in support calculation; without them appellate review is impossible | Court held Rule 52(a) required findings; denial was error, so child support portion vacated and remanded for findings |
| Whether the court’s determinations of parties’ incomes and childcare expense were supported by the record (voluntary underemployment, treatment of bonuses/expenses, childcare days) | Dumas contended her income and claimed business deductions were proper and she was not underemployed because she cared for a child under 3 | Milotte argued different income figures and that childcare level (five days) was unsupported; he sought findings on underemployment and expense treatment | Court did not resolve merits on appeal because lack of findings prevented review; remanded for the court to make explicit findings and conclusions |
Key Cases Cited
- Young v. Young, 120 A.3d 106 (Me. 2015) (Rule 52(a) requires findings sufficient to inform parties of the court’s reasoning and allow appellate review)
- Dargie v. Dargie, 778 A.2d 353 (Me. 2001) (court must explain basis for child support computations tied to factual findings)
- Sheikh v. Haji, 32 A.3d 1065 (Me. 2011) (discusses treatment of voluntary underemployment in child support income determinations)