James A. Sulikowski v. Sandra L. Sulikowski, 216 A.3d 893

James and Sandra Sulikowski divorced in 2014; the decree set James’s income at $98,500 and imputed Sandra’s income at $38,000 and allocated healthcare/orthodontic expenses (James 72%, Sandra 28%).
Sandra moved to modify child support (alleging James’s income rose); James moved to terminate spousal support (alleging Sandra’s income rose and she was cohabiting).
At a consolidated hearing the parties presented competing income evidence: Sandra testified to annual income roughly $32k–$48k; a forensic accountant estimated Sandra’s income much higher; James’s average income for 2014–2017 was found to be $120,247.
The District Court found James’s gross income $120,247 and Sandra’s gross income $76,000, reduced but did not terminate spousal support, and ordered certain spousal repayment; it denied attorney fees to both parties.
The court’s child support calculation used the two-child table (instead of three), misallocated medical/orthodontic shares on the worksheet, and contained arithmetic errors; both parties appealed.
The Supreme Judicial Court affirmed all rulings except it vacated the child support order and remanded for correction of the arithmetic and allocation errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Court erred in determining James’s income	Sandra: the court miscalculated/imputed income incorrectly	James: finding of $120,247 supported by averaging prior years and expert evidence	No clear error — finding supported by competent evidence
Court erred in determining Sandra’s income	Sandra: court wrongly fixed gross income at $76,000	James: court properly rejected Sandra’s underreported figures based on forensic evidence	No clear error — $76,000 supported; credibility determinations permissible
Child support computation and allocations	Both parties: worksheets contain computational and allocation errors	Both parties agreed errors existed and identified misallocations	Court committed arithmetic errors (used 2-child instead of 3-child table; misallocated medical and orthodontic expenses); child support order vacated and remanded for recalculation
Denial of attorney fees / self-effectuating order	Parties sought fees; both requested a self-effectuating support provision	Trial court declined fees and refused to issue a self-effectuating order	Denial of fees affirmed (no abuse of discretion); court properly declined to adopt a blanket rule requiring self-effectuating orders

Ehret v. Ehret, 135 A.3d 101 (standard for reviewing spousal-support modifications and factual findings)
Klein v. Klein, 208 A.3d 802 (trial court may accept or reject witness testimony and credibility findings)
Theberge v. Theberge, 9 A.3d 809 (no requirement that court state its reasoning for each factual finding)
Foley v. Ziegler, 931 A.2d 498 (computational child-support errors may be remanded for correction)
Sullivan v. Tardiff, 124 A.3d 652 (standard of review for child support modifications)
Urquhart v. Urquhart, 854 A.2d 193 (attorney-fee awards may be based on relative financial ability; reviewed for abuse of discretion)
Higgins v. Wood, 189 A.3d 724 (discussing when self-effectuating support provisions may be appropriate)