In RE the Marriage of Arleen Marie Vaughan and Philip James Vaughan, Upon the Petition of Arleen Marie White-Vaughan
2012 Iowa Sup. LEXIS 41
| Iowa | 2012Background
- Iowa Supreme Court reviews whether a postsecondary education subsidy under Iowa Code section 598.21F may be ordered and, if so, the amount.
- Prior district court ordered both parents to pay the maximum subsidy (one-third of remaining cost) for Allison Vaughan at Iowa State University.
- Allison is 19, attending ISU, contributing an estimated $5000/year from earnings, with total costs around $22,822/year.
- Philip Vaughan has limited cash flow and modest net worth; Arleen Wentworth-Vaughan has substantial apparent resources.
- Court finds good cause exists for a modest subsidy and reduces the award from the district court’s amount to a monthly $150 payment by Philip.
- Judgment of the court of appeals is vacated; district court judgment affirmed as modified; costs borne by Arleen.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether good cause exists for a postsecondary subsidy | Vaughan asserts good cause due to Allison’s age, ability, need, and lack of self-sufficiency. | Wentworth-Vaughan contends limited resources negate good cause for subsidy. | Good cause exists for a modest subsidy. |
| What amount constitutes a modest, non-hardship subsidy | Plaintiff argues the statutory cap permits substantial support to ensure education. | Defendant argues financial hardship should limit any subsidy. | Amount set at $150 per month from Philip. |
| Whether subsidy allocation respects the financial condition of both parents | Philip should bear his portion given income and assets. | Arleen’s finances are stronger; subsidy should reflect both parents’ ability to pay. | Allocation limited by Neff/Longman framework to a modest share. |
Key Cases Cited
- In re Marriage of Gerk, 259 Iowa 293 (Iowa 1966) (education may be a necessary part of support in proper cases)
- Sandler v. Sandler, 165 N.W.2d 799 (Iowa 1969) (parents’ financial condition informs subsidy amounts)
- Beasley v. Beasley, 159 N.W.2d 449 (Iowa 1968) (financial condition guides subsidy magnitude)
- In re Marriage of Vrban, 293 N.W.2d 198 (Iowa 1980) (constitutional consideration of postminority support)
- In re Marriage of Longman, 619 N.W.2d 369 (Iowa 2000) (no equal sacrifice required as with child support)
- In re Marriage of Neff, 675 N.W.2d 573 (Iowa 2004) (modest subsidy may be appropriate despite limited resources)
- In re Marriage of Vannausdle, 668 N.W.2d 885 (Iowa 2003) (child’s contributions considered; loans not a factor here)