Davis v. Knafel

MATHIAS, Judge,

dissenting.

I respectfully dissent from the majority's conclusion that the trial court erred in modifying Davis's child support obligation. I agree with the majority's recognition of the importance of MacLafferty. However, I disagree with the majority's interpretation of that case.

In MacLofferty, the trial court granted Father's request to decrease his weekly child support obligation because Mother obtained full-time employment and her income more than doubled. However, Mother's income increased from only $16,848 to $36,868 per year, while Father's income, minus any bonus compensation, increased from $118,924 to $125,164. Id. at 989. Our supreme court reversed the trial court's order and noted that even with the increase in her income, "Mother's income was quite modest compared to Father's: Father's income (excluding bonuses) was approximately 3-1/4 times that of Mother. We hold that the change alleged here was not so substantial as to render the terms of the prior order unreasonable." Id. at 942.

Concerning the issues presented in this appeal, the MacLofferty court indicated that in most cases, a change in income will generally not justify a modification of child support under Indiana Code section 31-16-8-1(1), which requires a showing of "changed cireumstances so substantial and continuing as to make the terms unreasonable." However, and most importantly regarding the case before us, the court also stated, "we do not hold that a modification may never be made under subsection (1) where the changed circumstances alleged is a change in one parent's income that only changes one parent's payment by less than 20%. There may be situations where a variety of factors converge to make such a modification permissible under the terms of the statute. While we do not find this case to be such a situation, we do not foreclose such a possibility." Id.

The focus of child support, whether pertaining to a child born within a marriage or out of wedlock, has always been to assure the child of a standard of living approaching the lifestyle the child would have enjoyed had his or her parents been and remained married through his or her minority. See Ind.Code § 31-14-11-2 (1998 & Supp.2005) (The paternity child support standard clearly focuses on "the standard of living the child would have enjoyed had the parents been married and remained married to each other.").

Davis was a well-paid professional athlete when T.D. was born and the lifestyle *591T.D. would have enjoyed had Davis and Knafel been and remained married throughout T.D.'s minority is beyond even the imagination of most Hoosiers. Yet that standard of living, along with Knafel's financial resources, T.D.'s physical and mental condition, T.D.'s educational needs, and Davis's financial resources and needs are the criteria the General Assembly has established for calculating child support. See Ind.Code § 81-14-11-2.

Since the original agreed order in paternity and agreed child support order, Davis's income has increased by 48.5 percent. His current annual income is $10,068,750. Due to the majority's reversal of the child support modification, Davis's child support obligation will return to $760 per week, or $39,520 per year, which is substantially less than one-half of one percent (39 percent) of Davis's eur-rent annual income.3 Mother earns less than $40,000 per year.

In light of the statutory criteria established in Indiana Code section 31-14-11-2, the vast disparity in the parties' incomes, and the more than forty percent increase in Davis's income since the entry of the original support order, I believe that the cireumstances presented here create precisely the situation contemplated in MacLafferty, where a change in income is sufficient to support a modification under subsections one of Indiana Code sections 31-16-8-1 or 31-14-11-8. Moreover, as the trial court noted, given Davis's considerable income and the substantial increase in his income over the last few years, his standard of living is well above that which is enjoyed by his child, T.D. Accordingly, I agree with the trial court's conclusion that "an increase in [Davis's] income in the amount of $2,752,870.60 per year is a substantial change in cireumstances ... [and] the existing support order of $760 per week is clearly unreasonable." See Appellant's App. p. 30. I believe to conclude otherwise betrays the underlying equitable intent of child support in Indiana and sends the wrong message to parents like Mr. Davis about the ongoing obligations they should expect regarding their children.

. The modified support obligation of $2308 per week, or $120,016 per year, amounts to just 1.19 percent of Davis's current annual income.