437 S.W.3d 404
Mo. Ct. App.2014Background
- Mother appeals the trial court's amended judgment of modification entered May 22, 2013.
- The trial court prepared its own Form 14 using Mother's gross income of $1,035 and Father's of $3,000, with Line 2(c)(i)=0 and Line 2(c)(ii)= $595, and no Line 6(a) work-related childcare adjustment.
- The August 6, 2013 amended judgment granted joint physical and legal custody to Father, with Mother's address for mailing and educational purposes, and set child support at $470.
- Prior paternity order (2009) required Father to pay $156/month and granted him no visitation.
- Trial occurred April 17, 2013; Father testified about a new child on the way; Mother testified about employment and childcare costs; Child would start kindergarten in the fall reducing daycare needs.
- Court of Appeals reverses and remands for recalculation of Form 14 Line 2(c) and Line 11; other aspects affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Form 14 Line 2(c) adjustment improper | Williams argues Line 2(c)(ii) should be zero. | Jones contends Line 2(c)(ii) reflects shared custody effects. | Line 2(c)(ii) miscalculated; credit should be zero. |
| Line 6(a) work-related childcare adjustment supported by substantial evidence | Williams asserts no substantial evidence supports excluding childcare costs. | Jones asserts evidence supports excluding costs due to upcoming school start. | Not error; substantial evidence supports exclusion. |
| Line 11 overnight adjustment improper given income | Williams argues no overnight credit due to income below threshold. | Jones argues Line 11 credit appropriate with overnight custody. | Line 11 adjustment improper; no overnight credit given income <$1,350. |
Key Cases Cited
- Woolridge v. Woolridge, 915 S.W.2d 372 (Mo.App.W.D.1996) (prescribes Form 14 calculation and unjust/inappropriate amount review)
- Samples v. Kouts, 954 S.W.2d 59B (Mo.App.W.D.1997) (rejects incorrect Form 14 items or math errors)
- Cross v. Cross, B18 S.W.3d 187 (Mo.App.W.D.2010) (Line 2(c) other-children credit guidance)
- Harrison v. Harrison, 871 S.W.2d 644 (Mo.App.S.D.1994) (Form 14 work-related childcare allocation guidance)
- Adams v. Adams, 414 S.W.3d 29 (Mo.App.S.D.2013) (Line 11 overnight credit threshold for income)
- J.A.R. v. D.G.R., 426 S.W.3d 624 (Mo.banc 2014) (substantial evidence standard in family‑law determinations)
- Lagermann v. Lagermann, 109 S.W.3d 239 (Mo.App.E.D.2003) (formula interpretation in Form 14 calculations)
- Heckman v. Heckman, 422 S.W.3d 336 (Mo.App.W.D.2013) (review of Form 14 calculations for mathematical accuracy)