Crystal Lancaster v. Erik S. Lancaster
228 So. 3d 1197
| Fla. Dist. Ct. App. | 2017Background
- Divorce final judgment between Crystal Lancaster (wife) and Erik Lancaster (husband) was entered by the Suwannee County circuit court.
- Parties had a negotiated settlement agreement incorporated into the final judgment providing that neither parent would pay child support to the other.
- Wife appealed, arguing the trial court erred by deviating from child support guidelines and denying child support to the detriment of the children.
- Husband defended the judgment, asserting the court properly incorporated the parties’ agreement eliminating reciprocal child support obligations.
- The trial court concluded the no-support arrangement was in the children’s best interests but did not make findings addressing children’s needs, parties’ finances, or the factors in section 61.30.
- The appellate court found the record lacked information showing the trial court independently assessed whether waiving support served the children’s best interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly incorporated an agreement waiving child support | Lancaster (wife): Court erred by deviating from guidelines and denying child support, harming the children | Lancaster (husband): Final judgment correctly incorporated parties’ negotiated agreement waiving reciprocal support | Reversed child-support provision and remanded because court failed to independently evaluate children’s needs and relevant statutory factors |
| Whether parents can contract away child support rights of their children | Wife: Parents cannot waive child support to children’s detriment | Husband: Agreement between parents governs obligations | Court: Parents cannot contract away a child’s statutory right to support; court must independently assess whether agreement serves child’s best interests |
| Whether guideline methodology was considered when parenting time is shared | Wife: Court should apply section 61.30 methodology and guideline presumptions | Husband: Agreement supersedes guideline calculation | Court: Guidelines are the starting point; deviation requires findings. Remand needed to apply appropriate methodology and make findings |
| Adequacy of trial-court findings for deviation from guidelines | Wife: No findings on needs or finances; decision not reviewable without record | Husband: Incorporation of agreement suffices | Court: Written findings explaining deviation or why guideline would be unjust/inappropriate are required; absence of such findings requires reversal/remand |
Key Cases Cited
- Cross v. Cross, 490 So. 2d 958 (Fla. 1st DCA) (trial court must independently evaluate child-support provisions in settlement agreements)
- Wendel v. Wendel, 852 So. 2d 277 (Fla. 2d DCA) (same principle regarding court’s duty before incorporation)
- Dep't of Revenue v. Reyes, 181 So. 3d 1270 (Fla. 1st DCA) (child support is a right belonging to the child; parents may not waive it)
- Imami v. Imami, 584 So. 2d 596 (Fla. 1st DCA) (child’s right to support belongs to the child rather than the parent)
- Armour v. Allen, 377 So. 2d 798 (Fla. 1st DCA) (parents cannot contract away child-support rights)
- Serio v. Serio, 830 So. 2d 278 (Fla. 2d DCA) (same restriction on parental waiver of child support)
- Morrow v. Frommer, 913 So. 2d 1195 (Fla. 4th DCA) (section 61.30 guidelines are the starting point for child-support determinations)