Florida child support guidelines must be attached to order
Posted by Nydia Streets of Streets Law in Florida Child Support
How important are child support guidelines in a Florida paternity case? The Florida child support guidelines are used to calculate what is considered an appropriate level of financial support for children in Florida, taking into account the incomes of the parents, health insurance premiums for the children, daycare costs, and the time-sharing schedule, among other matters. The case Minus v. Brockman, 4D21-1615 (Fla. 4th DCA October 6, 2021) involves a missing child support guidelines worksheet.
This case does not report much in the way of background information on the parties or what happened at the trial level. However, the mother appealed the final judgment of paternity because there was no child support guidelines worksheet attached to the final judgment and no parenting plan was included in the record.
The appellate court noted that although a transcript of the proceeding was not provided (which is usually fatal to an appeal), the errors complained of were evident on the face of the judgment, and the father conceded these errors. The court held “An order granting child support must be reversed where a child support guidelines worksheet is not attached to the final judgment. Dep’t of Rev. ex rel. K.A.N. v. A.N.J., 165 So. 3d 846, 848 (Fla. 2d DCA 2015); Fla. Fam. L. R. P. 12.285(k). Reversal is also required in the absence of a parenting plan. Munroe v. Olibrice, 83 So. 3d 985, 987 (Fla. 4th DCA 2012).”
If you need help calculating child support in your Florida family law case, schedule a consultation with a Miami family law attorney for assistance.