Jaylo v. Jaylo
Annotate this CaseFather and Mother were divorced pursuant to a divorce decree that ordered Father to pay child support for each child as long as they continued post-high school education, until graduation, or until the child attained the age of twenty-three. The family court later granted Mother's post-decree motion seeking an order reestablishing educational support for the parties' twenty-five year-old daughter, who was legally blind and pursuing a college education. The intermediate court of appeals (ICA) remanded. At issue on appeal was whether Haw. Rev. Stat. 580-47(a) authorized a family court to order educational support for a disabled but competent child age twenty-three or older when the family court's 2004 Child Support Guidelines provided that such support may be continued only until the child reaches age twenty-three. The Supreme Court vacated the ICA and affirmed the family court, holding (1) to the extent that the 2004 Guidelines purport to set an age limitation on the family child's authority to continue educational support for an adult child, they are invalid as they exceed the statutory mandate of section 580-47(a); and (2) section 580-47(a) does not impose an age limit for educational support of a child age twenty-three or older.
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