Coleman v. McCullough, 290 P.3d 413

Coleman is the biological father of two minor sons, T.C. and J.C.
T.C. was born January 2000 to Elka McCullough, with whom Coleman had a brief relationship.
J.C. was born March 2000 to Laura Bianchi, with whom Coleman had a long-term relationship and with whom he cohabitated at trial.
McCullough petitioned for child support for T.C.; Coleman did not contest the support amount but sought a 90.3(a)(1)(D) deduction.
Coleman argued he should deduct support for J.C. as a subsequent child in a prior relationship while residing with J.C.
The superior court ruled against Coleman, and the Alaska Supreme Court affirmed the ruling on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 90.3(a)(1)(D) allows a deduction for a child from a prior relationship who is born after the supported child	Coleman argues the deduction applies to J.C.	McCullough argues no deduction for J.C.	No deduction for J.C.; duty begins at each child's birth, not from prior relationships.

Skinner v. Hagberg, 183 P.3d 486 (Alaska 2008) (duty of support begins at birth; cannot retroactively adjust)
Kestner v. Clark, 182 P.3d 1117 (Alaska 2008) (rule interpretation guiding 90.3 adjustments)
Joseph v. State, 26 P.3d 459 (Alaska 2001) (cited for statutory interpretation principles)
Ford v. Municipality of Anchorage, 813 P.2d 654 (Alaska 1991) (statutory interpretation principles)
Thoeni v. Consumer Elec. Servs., 151 P.3d 1249 (Alaska 2007) (support considerations and exceptions)
Matthews v. Matthews, 739 P.2d 1298 (Alaska 1987) (traditional presumptions on support obligations)