Justia Family Law Opinion Summaries

Philip Vaughan and Arleen Wentworth divorced pursuant to a divorce decree that ordered Philip to pay child support until the couple's child, Allison, turned twenty-two if Allison continued a course of higher education. Philip later initiated the present proceeding, asserting that his child support obligation terminated when Allison reached eighteen. Arleene filed a cross-petition asking that Philip be required to pay the statutory maximum of postsecondary education subsidy under Iowa Code 598.21F. After both parties stipulated to certain facts, the litigation focused on whether the court should order Philip to also pay a postsecondary education subsidy and, if so, in what amount. The district court concluded that good cause existed for a postsecondary education subsidy and ordered both parents to pay the statutory maximum of one-third of the remaining cost of Allison's education. The court of appeals affirmed. Philip appealed. The Supreme Court (1) affirmed the determination that good cause existed for payment of a modest postsecondary education subsidy; but (2) reduced the amount awarded by the district court, holding that there was good cause to require Philip to provide a modest postsecondary education in this case.

Kathy Morris and Dennis Morris divorced in 2003 pursuant to a stipulated decree of dissolution adopted by the district court. Trial counsel for the parties did not expressly address survivor rights when dividing retirement benefits. At issue was whether the award of "half of the...Marine Corps Retirement" in the parties' stipulated decree entitled Kathy to fifty percent of Dennis's retirement benefits while Dennis lived, without survivor benefits, or whether the decree obligated Dennis to designate Kathy for survivor benefits. In 2010, Kathy filed an application for a hearing to decide the issue. The district court denied Kathy relief, and the court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the trial court, holding that the lower courts erred by characterizing the issue solely as a request for modification of the 2003 decree. Rather, the disputed should have been treated as a request to interpret the 2003 decree. Remanded for the district court to determine its intent as to survivorship rights when it entered the decree in 2003.

The juvenile court terminated the noncustodial mother's parental rights to two children after finding termination was in the children's best interests. The court of appeals reversed, giving weight to the fact that termination would end the mother's child support payments. The father of one child filed a timely application for further review, and the other father did not. The Supreme Court vacated the court of appeals and affirmed the juvenile court as to the child whose father filed the application for further review and affirmed as to the other child, holding that the elimination of possible child support may not affect a termination of parental rights proceeding if termination is otherwise in the child's best interests.