Mandy Valentine v. Dan Valentine
162 Idaho 86
Idaho Ct. App.2017Background
- Mandy and Dan Valentine divorced after marriage and two children; dispute concerned calculation of Dan’s child support.
- Issue centered on whether employer-paid health insurance premiums should be counted as income (fringe benefit) under Idaho Child Support Guidelines (I.F.L.R.P. 126(F)).
- Magistrate excluded the employer contribution from Dan’s income for child support; district court affirmed on intermediate appeal.
- Mandy argued ACA’s individual mandate increased personal living expenses, so employer-paid premiums are a significant fringe benefit that reduces living expenses and must be included.
- Magistrate found health insurance contributions are not among the examples of fringe benefits in Rule 126(F)(2) and thus not a fringe benefit for inclusion; appellate courts affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether employer-paid health insurance premiums are a "fringe benefit" under I.F.L.R.P. 126(F)(2) for calculating child support income | Mandy: ACA’s mandate raises personal living expenses; employer-paid premiums therefore are a significant fringe benefit that reduces living expenses and should be counted as income | Dan: Employer contributions are not the kind of fringe benefits listed or contemplated by Rule 126(F)(2); magistrate properly excluded them | Held: Not a fringe benefit under Rule 126(F)(2); magistrate’s exclusion affirmed |
Key Cases Cited
- Pelayo v. Pelayo, 154 Idaho 855 (review standard for magistrate findings and district court appellate role)
- Kornfield v. Kornfield, 134 Idaho 383 (interpretation of child support guidelines is a question of law)
- Noble v. Fisher, 126 Idaho 885 (plain-language interpretation of rules)
- Sun Valley Shopping Ctr., Inc. v. Idaho Power Co., 119 Idaho 87 (standard for review of discretionary decisions)