In Re the Marriage of Wells, 252 P.3d 1212

Post-dissolution dispute over Scott Wells's child support with Carrie Wells for two children.
Husband challenged the trial court’s order: (i) to modify child support using two worksheets; (ii) to award extraordinary expenses for the teen son’s car; (iii) to award wife attorney fees for discovery noncompliance.
Trial court calculated support via separate worksheets for each child and then deviated downward without explicit findings.
Court found extraordinary expenses related to the son’s car appropriate in light of transportation needs and lack of school bus service.
Court awarded wife attorney fees for discovery noncompliance; husband argues lack of timely response and conferencing.
Appellate court reverses the child support portion, remands for recalculation using one worksheet and Quam-based credits; affirms extraordinary expenses and attorney-fee rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether two worksheets were proper for two children under shared parenting time	Wells argues multiple worksheets inflated obligations and deviates from guideline structure.	Wells argues court’s dual-worksheet method reflects different child circumstances.	Reversed; use one worksheet with Quam crediting on remand.
Whether deviation from guidelines was justified and adequately found	Wells contends downward deviation lacked supporting findings.	Wells asserts the court’s deviation was appropriate under inequity considerations.	Remand for proper findings and explanation of any deviation.
Whether extraordinary expenses for the teen’s car were properly awarded	Wells contends car costs for a student-transport need are not properly allocated to him.	Wells acknowledges transportation necessity but disputes prior car provision and ongoing costs.	Affirmed; award upheld under § 14-10-115(11)(a)(I) with proportional sharing.
Whether attorney fees for discovery noncompliance were proper sanctions	Wells argues sanctions were improper or premature due to lack of response opportunity.	Wells contends noncompliance justified sanctions.	Affirmed; trial court's sanctions within discretion; arguments not preserved on appeal.

In re Marriage of Atencio, 47 P.3d 718 (Colo. App. 2002) (guidelines review for abuse of discretion; de novo for legal standard)
In re Marriage of Emerson, 77 P.3d 923 (Colo. App. 2003) (shared parenting time and deviations from guidelines)
In re Marriage of Quam, 813 P.2d 833 (Colo. App. 1991) (Quam formula for crediting partial overnights when one child visited)
Combs v. Tibbitts, 148 P.3d 430 (Colo. App. 2006) (deviations from guidelines require findings)
In re West, 94 P.3d 1248 (Colo. App. 2004) (extraordinary expenses require supporting findings and evidence)
Estate of Stevenson v. Hollywood Bar & Cafe, Inc., 832 P.2d 718 (Colo. 1992) (preservation of arguments listed in trial court)
O'Connell v. Biomet, Inc., 250 P.3d 1278 (Colo. App. 2010) (arguments not raised below are waived on appeal)