Lynn Marie Larsen v. Roger Wayne Larsen, 912 N.W.2d 444

Lynn and Roger Larsen divorced in 2015 and entered a partial stipulation requiring parental contributions to any child’s postsecondary education; each parent controls half of the child’s §529 funds.
Daughter H.M. (b. 1997) enrolled at Iowa State for the 2016–2017 year in a five‑year architecture program.
Dispute arose over the amount each parent must pay under Iowa Code §598.21F after the district court included sorority dues and excluded certain child resources; district court ordered each parent to pay $6,629.73; court of appeals affirmed.
Key contested points: proper presumptive cost of attendance, inclusion of sorority dues and cash allowance, whether to count scholarships, declined unsubsidized loans, part‑time earnings, summer work, child support, and the child’s bank balance and §529 funds.
Supreme Court reviewed de novo, held the institutional published cost of attendance is presumptively the reasonable cost, adjusted child contribution for earnings and savings, and remanded with a revised parental share of $6,362.50 each.

Issue	Plaintiff's Argument (Lynn)	Defendant's Argument (Roger)	Held
Appropriate baseline cost of attendance	Use Iowa State’s published cost; sorority dues may be included	Exclude sorority dues and any expenses beyond necessary costs	Institutional published cost of attendance is presumptive; no showing to vary; use $19,750 and exclude added sorority dues
Treatment of scholarships and other financial aid	Treat scholarships as child contribution under step two	Some scholarship treatment belongs in step one; include declined unsubsidized loans as the child’s contribution	Scholarships count as child contribution; declined unsubsidized loans not reasonably required to include given §529 balance and parents’ resources
Inclusion of child’s potential earnings and bank balance	Include realistic earning ability and modest use of savings	Child’s job uncertain; include larger estimated earnings and bank funds to eliminate parental obligation	Court may impute modest earnings ($1,500 total from work and $500 from savings) as reasonable child contribution
Calculation of each parent’s share and statutory cap	Divide residual cost after child contribution and available §529 resources; each pays up to one‑third cap	Subtract all available resources to reduce/eliminate parental obligation	After subtracting child contribution, divide remaining cost in half; resulting parental shares ($6,362.50) do not exceed one‑third cap, so each parent pays that amount

In re Marriage of Neff, 675 N.W.2d 573 (Iowa 2004) (loans may be included in student contribution only when reasonable under facts)
In re Marriage of Vaughan, 812 N.W.2d 688 (Iowa 2012) (standard for de novo review in dissolution appeals)
In re Marriage of Olson, 705 N.W.2d 312 (Iowa 2005) (appellate review gives weight to trial findings but is not bound by them)
In re Marriage of Goodman, 690 N.W.2d 279 (Iowa 2004) (factors to determine good cause for postsecondary subsidy)
Johnson v. Louis, 654 N.W.2d 886 (Iowa 2002) (upholding constitutionality of postsecondary subsidy statute)
In re Marriage of Vrban, 293 N.W.2d 198 (Iowa 1980) (constitutional discussion of subsidy statute)
Curtis v. Kline, 666 A.2d 265 (Pa. 1995) (court case questioning constitutionality of forced postsecondary support)