MICHELE KRIEGMAN VS. TARA SAE-CHIN(FM-14-136-97, MORRIS COUNTY AND STATEWIDE)Â (CONSOLIDATED), A-2039-14T3/A-5032-14T3/A-5033-14T3/A-5034-14T3

Background

Kriegman and Sae-Chin divorced in 1998 and their Property Settlement Agreement (PSA) governed child support and college expense allocation for three children: Abigail, Elanya, and Derek. Emancipation under the PSA occurs at age 22 or after four continuous college years (with limits on gap years).
Post-judgment orders (2005 consent order, 2006, 2013, 2014, and 2015 orders) changed custody, support credits, and allocated college expense percentages; litigation continued over reimbursements, offsets, and alleged arrears.
A 2005 CPA allocation (18% plaintiff / 82% defendant) was used for specific 2005 expenses (medical, camp) but not explicitly for all historical expenses.
In October 2014 the trial court issued an opinion awarding and offsetting various tuition/expense claims, ordering plaintiff to reimburse defendant $13,516.45 and to pay part of Derek’s Villanova tuition; the opinion lacked detailed factual findings for many amounts.
Subsequent January and March 2015 orders enforced portions of the October 2014 judgment, terminated child support for Derek retroactive to October 2014, and found an additional overpayment — rulings the Appellate Division later reviewed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Abigail should be retroactively emancipated and whether credits are due to plaintiff for resulting support adjustments	Kriegman argued Abigail de facto emancipated earlier; seeks $49,500 credit based on alleged weekly offsets and wants retroactive recalculation	Sae‑Chin relied on consent emancipation in 2013 and offsets awarded; trial judge treated claim as waived	Court: Plaintiff’s waiver finding unsound as a legal bar; remanded for the judge to determine credits, if any, due from Abigail’s retroactive emancipation (insufficient factual/ legal analysis below)
Whether trial court properly calculated and assigned credits/obligations for Derek’s and Elanya’s tuition and college expenses	Kriegman contends judge overlooked/excluded documented expenses and miscalculated awards and percentages	Sae‑Chin relied on trial findings and exhibits showing payments; trial court awarded certain sums to both sides	Court: Reversed and remanded — trial judge failed Rule 1:7‑4 factfinding and did not explain allocations, proofs relied on, or financial‑circumstance analysis needed to apportion college costs
Whether Derek was properly emancipated effective Oct. 14, 2014 and child support terminated	Kriegman argued Derek’s emancipation per PSA should be May 2015 (expected graduation) and that retroactive emancipation was improper	Sae‑Chin obtained trial court orders declaring earlier emancipation and overpayment credits	Court: Reversed emancipation & termination — record lacks basis to declare Derek emancipated Oct. 2014; orders vacated
Whether plaintiff is entitled to credits for defendant’s unexercised overnight parenting time and whether expenses withheld without consent should be charged to defendant	Kriegman sought credit for defendant’s unexercised overnights (claimed 36% credit) and argued defendant unreasonably withheld consent for various non‑college expenses	Sae‑Chin argued no modification agreement and that plaintiff failed to mediate per PSA or timely raise claim	Court: Affirmed denial of credit for unexercised overnights (no agreement to adjust support based on actual overnights); affirmed denial of claimed expenses where plaintiff failed to show unreasonable withholding and trial court’s findings were adequate as to those claims

Key Cases Cited

Jacoby v. Jacoby, 427 N.J. Super. 109 (App. Div. 2012) (appellate standard: review abuse of discretion for child support matters)
Strahan v. Strahan, 402 N.J. Super. 298 (App. Div. 2008) (failure to make specific Rule 1:7‑4 findings requires remand)
Heinl v. Heinl, 287 N.J. Super. 337 (App. Div. 1996) (naked conclusions insufficient; judges must articulate specific findings)
Rova Farms Resort, Inc. v. Inv’rs Ins. Co. of Am., 65 N.J. 474 (1974) (reversal warranted if findings are manifestly unsupported by credible evidence)
Reese v. Weis, 430 N.J. Super. 552 (App. Div. 2013) (legal conclusions reviewed de novo)
Konzelman v. Konzelman, 158 N.J. 185 (1999) (courts must enforce fair and equitable divorce settlements governing child support)