In the Matter of the Petition for Child Support of SAMANTHA SNODDERLY v. BRADLEY SHOCKEY
No. 86913-2-I
IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE
7/21/2025
SMITH, J.
UNPUBLISHED
SMITH, J. — Samantha Snodderly and Bradley Shockey share one child together, D.S. In 2022, the Division of Child Support issued an agreed settlement addrеssing child support obligations. In 2024, when D.S. was 18 years old but still in high school, Snodderly petitioned to obtain post-secondary child support. The trial court denied and dismissed Snodderly‘s pеtition, stating it did not have authority to order post-secondary support because the child was emancipated. Snodderly appealed.
Because the administrative order of child support is a written agreement for purposes of
FACTS
Samantha Snodderly and Bradley Shockey share one child together, D.S. In 2006, when D.S. was born, Snodderly and Shockey signed and filed an acknowledgment of parentage with the appropriate agency. In 2011, Snodderly and Shoсkey entered into an administrative order of child support, issued by Division of Child Support (DCS). In June 2022, they entered into an agreed settlement with DCS modifying their support obligations concerning D.S. The agreed settlement of child support included duration provisions for the order.
The agreement specified:
The current child support and health care coverage obligations in this settlement / order continue each month until one of the following occurs:
- (1) A state or tribal court order supersedes this order.
- (2) This order is modified under
WAC 388-14A-3925 . The noncustodial parent, physical custodian, or DCS may petition for modification.- (3) A child turns 18, or graduates from a secondary school program or the same level of vocational or technical training, which is later, if the child is a full-time student and has not reаched age 19.
In February 2024, Snodderly petitioned the court to establish a child support order and obtain post-secondary support for D.S.1 The administrative order was still in еffect when Snodderly filed the petition. At the time, D.S. was 18, but had not yet graduated high school. Shockey was personally served, but never responded to the petition. Snodderly obtained an order of default in March 2024.
In May 2024, Snodderly and Shockey appeared before the court, where Snodderly presented final orders. The trial court set a
At the hearing, the court determined it did not have jurisdiction to enter a parenting plan and did not have authority to enter an order for post-secondary suрport because D.S. was emancipated and the agreed settlement was not considered a “written agreement” for purposes of
ANALYSIS
Snodderly claims the trial court abused its discretion when it determined D.S. was an emancipated adult and concluded it did not have jurisdiction to order post-secondary support. Because D.S. was dependent on his parents for support and the administrative order of child support was a valid, written agreement for purposes of
We review a trial court‘s decision concerning modification of a child support order for abuse of discretion. In re Marriage of Littlefield, 133 Wn.2d 39, 46, 940 P.2d 1362 (1997). “A court abuses its discretion when its decision is manifestly unreasonable or based on untenable grounds or reasons.” Matter of Marriage of Laidlaw, 2 Wn. App. 2d 381, 386, 409 P.3d 1184 (2018).
“A parent-child relationship extends equally to every child and parent, regardless of the marital status of the parent.”
Under
75 Wn. App. 776, 779, 880 P.2d 78 (1994) (citing Childers v. Childers, 89 Wn.2d 592, 597, 575 P.2d 201 (1978)). Accordingly, a parent may havе a continuing obligation to provide support for a child over the age of 18 if the order expressly provides for post-majority support. Balch, 75 Wn. App. at 779.
In accordance with
Here, DCS entered an agreed settlement in June 2022, that stated, “This Agreed Settlement is a child support order under
When the trial court considered Snodderly‘s petition for post-secondary support, it concluded the agreed settlement was not sufficient to preserve the issue of post-secondary support beyond the child‘s 18th birthday because the statute requires a court order to extend the cоurt‘s authority past the age of emancipation. And, because no court order addressing child support was in the record, the court reasoned it did not have authоrity to order post-secondary support.
The trial court believed “the administrative order on its own is not an order for purposes of [RCW] 26.09.170.” But this interpretation treats children whose support is ordered through the administrative process differently than children whose support is established by a dissolution decree, parentage action, оr by filing a petition for child support and a parenting plan. And it does not align with the intent of
Additionally, because an administrative order of child support is a “written agreement” for purposes of
When Snodderly petitioned to establish a child support order to obtain post-secondary child support, D.S. was 18 but still attеnding secondary school. And even though the trial court ruled that at the time the petition was filed, an administrative order of support existed—which provided it was valid until the child finished high school or turned 19 years old, whichever happened first—the court determined there was no written agreement in this case. Consequently, the court ruled D.S. was emancipated when he turned 18 years old, and it did not have authority to order post-secondary support. This determination was error. The language of the agreed settlement makes clear D.S. was still dependent when Snodderly filed the petition. The agreed settlement was a valid agreement in writing and, therefore, D.S. was not emancipated for рurposes of
Accordingly, the trial court abused its discretion when it dismissed Snodderly‘s petition for post-secondary support.
We reverse and remand for further proceedings consistent with this opinion.
WE CONCUR:
Feldun, J.
Díaz, J.