In the Matter of Susan J. Regan and Steven S. ReganAnnotate this Case
Respondent Steven Regan (father) appealed an order recommended by a Marital Master (and approved by the circuit court) that among other things: (1) declined to modify his obligations to carry life insurance and pay half of his minor daughter's uninsured medical expenses even though paying these amounts reduced his monthly income below the statutory self-support reserve; and (2) required him to exchange custody of his daughter at a police station, rather than at the parties' homes. Although the court found that the father's reduction in income required reducing his child support obligation, it found "no basis to modify" the father's obligation to pay for half of his daughter's orthodontic expenses, and similarly declined to reduce the amount of life insurance he was obliged to carry. Upon review, the Supreme Court concluded that payment of the daughter's uninsured medical expenses necessarily reduced the father's income below the self-support reserve and therefore, the trial court's order insofar as it required such payments, erred by ordering the father pay. With regard to the life insurance, because the parties stipulated that the payments were not child support, the trial court "sustainably exercised" its discretion in finding that the monthly insurance payment would not unduly burden the father's ability to support himself. Furthermore, with regard to the custody exchange: the Court concluded that making the exchange at a police station was in the daughter's best interest.