Paying Child Support For Children From Different Relationships

Grogan v. Grogan

Appeal from the Circuit Court of Howell County to the Missouri Court of Appeals – Southern District

No. SD36599

Filed February 25, 2021

Outcome: Affirmed in Part, Reversed in Part and Remanded

 

The parties T. Grogan (hereinafter “Mother”) and A. Grogan (hereinafter “Father”) separated in August of 2017. Father was ordered to pay $1081 per month in child support for their two children. Father had also been ordered to pay child support for his children from a previous marriage as well.

 

After the judgment was entered, Father’s child support obligation for his other children was reduced from $1100/month to $225/month. In a timely post trial motion, Mother asked the trial court to recalculate Father’s child support obligation using the reduced $225/month amount for his other children. The trial court’s denied Mother’s request to calculate child support using the $225/month amount on the Form 14. The Court entered a child support award using the $1100/month amount.

 

Mother appealed and the Appellate Court found the trial court abused its discretion in denying Mother’s timely request to recalculate the Form 14 using the $225/month in child support for Father’s other child support obligation for his other children.

 

The case was reversed and remanded for further proceedings consistent with this opinion. The other 3 points in Mother’s appeal are affirmed.