Valentine v. Valentine
Annotate this CaseMandy and Dan Valentine divorced in 2015. In 2017, Mandy petitioned the magistrate court for an order modifying the child custody and support provisions of the divorce decree. The magistrate court did not modify the custody provisions in the decree but concluded that substantial and material changes in circumstances existed to justify modifying the child support order. Mandy appealed several aspects of this ruling to the district court. The district court, sitting in an appellate capacity, affirmed in part and reversed in part the magistrate court’s order. On appeal to the Idaho Supreme Court, Mandy challenged the district court’s conclusion that her student loans and several other sources of income could be combined to calculate her income under the Idaho Child Support Guidelines. Dan cross-appealed, challenging the district court’s conclusion that the magistrate court abused its discretion in calculating his pro rata share of childcare expenses. The Supreme Court determined that while the district court correctly interpreted the Idaho Child Support Guidelines to require the inclusion of gross and, if applicable, potential income in the calculation of Guidelines Income, it erred in concluding that the magistrate court’s failure to make a finding that Mandy was voluntarily unemployed or underemployed before imputing potential income to her was harmless. Second, the district court erred in determining that the magistrate court abused its discretion in ordering Dan to pay his pro rata share of childcare expenses after subtracting the amount of Idaho Child Care Program benefits Mandy received from the total costs.
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