Y.R. v. A.F.

Mother of Z. appealed the trial court's order awarding child support from Father, a successful director and producer, in an amount that deviated downward from the statewide uniform guideline by a substantial amount. The court concluded that the trial court's failure to comply with the requirements of Family Code section 4056, subdivision (a), mandated reversal, despite the existence of evidence sufficient to warrant a deviation from the guideline; the trial court's reliance on Mother's and Z.'s expenses and lifestyle, rather than on those of Father and his children, precluded the court from implying findings adequate to support the deviation ordered by the court; and thus the court reversed and remanded for reconsideration of child support criteria under the correct criteria. View "Y.R. v. A.F." on Justia Law