Pearson v. Pearson, 285 Neb. 686

Kelly Pearson and Steven Pearson married in 1998; they have three minor children and resided in Nebraska.
A dissolution decree in 2008 provided joint custody with day-to-day decisions by the residing parent and no child support due to income and overnight schedules.
In 2011 Kelly moved to modify, seeking sole custody in Alaska based on her husband’s job opportunity and requested child support calculation under standard guidelines, retroactive to the modification filing.
The district court granted removal to Alaska, awarded Kelly sole custody, granted Steven summer and holiday visitation (including in Alaska with 48 hours’ notice for travel), and ordered Steven to pay all visitation transportation costs unless airline chaperones were required.
The court terminated Steven’s child support obligations due to increased visitation costs, but the order lacked the required child-support worksheets and methodology.
This appeal questioned whether termination of child support was appropriate and whether the court properly documented the calculation; the case was remanded for complete worksheets and a modification order consistent with Rutherford and related authorities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether terminating child support was an abuse of discretion	Pearson argues travel costs justify modification and termination of support.	Pearson contends increased visitation costs can support deviation but should be properly documented.	Remanded for proper worksheets and justification; not finally decided here.
Whether deviations from guidelines were properly authorized	Deviation allowed when guidelines would be unjust given visitation.	Deviation must reflect best interests and be supported by findings.	Guidelines deviations require explicit findings and alignment with best interests.
Whether travel expenses can constitute a deviation from guidelines	Travel costs directly associated with visitation may support deviation.	Only reasonable travel costs may reduce support; the record lacked calculations.	Travel costs may be considered, but need proper calculation and explanation.
Whether the record included required child-support worksheets	Record lacked the court’s worksheet; modification cannot be properly reviewed.	One worksheet prepared by respondent’s counsel was offered as aid, but not attached to order.	Remand to include complete worksheets and the method of calculation.

Rutherford v. Rutherford, 277 Neb. 301 (Neb. 2009) (requires complete worksheets; remand if missing)
Incontro v. Jacobs, 277 Neb. 275 (Neb. 2009) (guidelines presumptions and deviations)
Gress v. Gress, 271 Neb. 122 (Neb. 2006) (guideline deviations and best interests)
Pathammavong v. Pathammavong, 268 Neb. 1 (Neb. 2004) (treatment of support modifications and worksheets)
State on behalf of Buckhalter v. Buckhalter, 273 Neb. 443 (Neb. 2007) (guidelines framework and deviations)
Plymale v. Donnelly, 157 P.3d 933 (Wyoming 2007) (out-of-state authority on travel costs and support)