State of Missouri, Department of Social Services, Family Support Division v. Randy Jay Swank, D/B/A Swank Farms, 2016 Mo. App. LEXIS 1083

The Missouri Family Support Division issued an income withholding order in Dec. 2012 directing employer Randy Swank (R. Swank Farms) to withhold child support and arrears from employee Michael Silkwood.
Swank initially withheld payments in Jan–Feb 2013 but then stopped after Silkwood gave Swank a purportedly signed document from the obligee stating she released Silkwood from support and arrears.
The withholding order warned employers to contact the Division if they doubted its validity and stated employers who fail to withhold are liable for amounts that should have been withheld.
Swank did not contact the Division about the document and ceased withholding; the Division sued to enforce the withholding order under § 454.505.8.
The trial court found Swank acted in good faith after consulting his accountant and ruled for him; the Division appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an employer who receives a Division withholding order can rely on an employee’s document purporting to terminate support to stop withholding	Division: Employer is strictly liable for failing to comply with a proper withholding order and cannot rely on employee-provided documents	Swank: Good‑faith reliance on employee’s document (and consultation with accountant) excuses noncompliance	Employer is strictly liable; receipt of contrary employee information does not excuse failure to withhold

J & J Indus. Supply, Inc. v. Missouri Dep’t of Social Servs., 459 S.W.3d 478 (Mo. App. E.D. 2015) (employer has no standing to attack Division withholding orders; creates employer liability under § 454.505)
State Dep’t of Social Services, Family Support Division v. Centrec Care, Inc., 472 S.W.3d 648 (Mo. App. E.D. 2015) (standard for reviewing trial court judgment affirmed/quoted)
Murphy v. Carron, 536 S.W.2d 30 (Mo. banc 1976) (standard for appellate review of court judgments)