H.D. v. D.B. (Appeal from Cullman Juvenile Court: CS-10-98.01)., CL-2024-0904

H.D. (mother) and D.B. (father) share a child and were awarded joint legal and physical custody by a juvenile court in 2012, with the father ordered to pay $500/month in child support.
In November 2023, H.D. filed for contempt, alleging the father had not paid child support in over nine years, with $54,000 in arrears and $18,203 in interest.
Both parents submitted evidence of their current income; the mother had changed jobs and the father claimed $7,583/month income.
The father filed for sole custody and a modification of child support, seeking calculation under Alabama's Rule 32 guidelines.
The juvenile court ordered the arrearage be paid but declined to order any current child support, citing the shared custody arrangement, without providing written findings for this deviation from Rule 32.
H.D. appealed, arguing the court erred by not following Rule 32 or explaining the deviation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court err by deviating from Rule 32 child	Juvenile court failed to provide	Child support calculation should	Deviation from Rule 32 without written findings is error;
support guidelines without a written justification?	required findings for deviating.	change due to joint custody.	judgment reversed and remanded for compliance with Rule 32

Hutchins v. Hutchins, 637 So. 2d 1371 (Ala. Civ. App. 1994) (trial court must make a factual finding to rebut the presumption of the correctness of guideline calculations)
R.N.P. v. S.W.W., 389 So. 3d 1215 (Ala. Civ. App. 2023) (any deviation from child-support guidelines must be justified in writing)
J.M. v. D.V., 877 So. 2d 623 (Ala. Civ. App. 2003) (same principle—requirement for a written justification for deviations from guidelines)