In re the Marriage of: Chanel L. Welsh and Chris Welsh, 34392-8

Chris and Chanell Welsh divorced after separating in 2015; they have three children, including an infant with Cornelia de Lange Syndrome (CdLS) requiring extensive medical care and breastfeeding.
At trial, Chris worked full-time (32 hours/week) with gross monthly income ~$6,132; Chanell worked part-time (20 hours/week) with gross monthly income ~$2,654 and could earn ~$4,160 if she worked 32 hours/week.
The trial court imputed Chanell's income at part-time (20 hours/week) because her caregiving for the special-needs infant made full-time work unreasonable, but also prepared an alternate support schedule based on both parents working 32 hours/week to take effect when the infant could have overnight visits with Chris.
Chris sought a downward deviation in child support based on shared residential time with the two older children; the court postponed ruling on that deviation until Chanell could work full-time, citing the need to avoid leaving Chanell’s household with insufficient funds for the children’s basic needs.
The dissolution decree, parenting plan, and child support order were entered April 1, 2016; Chris appealed the child support determinations and sought attorney fees.

Issue	Plaintiff's Argument (Welsh)	Defendant's Argument (Chanell)	Held
Whether court properly imputed part-time income to Chanell	Court should impute full-time income; Chanell is underemployed	Underemployment is not voluntary given infant's special needs; part-time imputation appropriate	Imputation to part-time wages affirmed as not voluntary underemployment
Whether underemployment was voluntary	Implied: Chanell voluntarily limited work	Chanell limited work due to medical needs and breastfeeding; delegation unreasonable	Trial court discretion upheld; underemployment found not voluntary
Whether residential-time deviation should be granted now	Chris sought downward deviation for shared residential time	Deviation would leave Chanell's household with insufficient funds during her limited income period	Court properly postponed deviation until Chanell can work full-time
Whether attorney fees should be awarded on appeal	Chris requested fees	No legal basis shown to award fees to Chris	Request for attorney fees denied

In re Marriage of Griffin, 114 Wn.2d 772 (1990) (standard for appellate review of child support orders)
In re Parentage of O.A.J., 190 Wn. App. 826 (2015) (standard for reviewing factual findings and abuse of discretion in support matters)
In re Marriage of Brockopp, 78 Wn. App. 441 (1995) (discussion treating voluntary underemployment analogous to voluntary unemployment)