Posted by Nydia Streets of Streets Law in Florida Child Support

How important is a Florida child support guidelines worksheet? If one is not attached to the final judgment, the judgment is likely to be reversed on appeal. This was an issue in the case Rouson v. DOR, 2D2024-0107 (Fla. 2d DCA October 16, 2024).

In this administrative child support case, the father appealed because the lower court did not appropriately calculate retroactive support by taking into account his actual income during the retroactive period. He also argued that it was improper to fail to attach child support guidelines worksheets to the final judgment.

The appellate court agreed with the father on both issues. The court held “Here, the final order reflects that the Department was provided with records reflecting Rouson's actual income during the retroactive time period but that the Department failed to use this evidence to calculate his support obligation. We therefore reverse and remand for recalculation of the retroactive support award in accordance with section 61.30(1)(a).” The court concluded “Finally, as the parties correctly point out, the Department failed to incorporate a child support guidelines worksheet in the final order. Without a guidelines worksheet, we cannot determine whether an award of retroactive child support is supported by the evidence.”

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