Hanrahan v. Bakker (majority)Annotate this Case
In a discretionary appeal, at issue before the Pennsylvania Supreme Court was whether the high income child support guidelines found at Pa.R.C.P. 1910.16-3.1 inherently accounted for the reasonable needs of the children such that any discrete analysis of those needs by a fact-finder was improper. The Court also examined whether a voluntary contribution to an irrevocable non-grantor trust for the benefit of the children was an appropriate factor for a court to consider for purposes of deviating from the guidelines amount of child support under Pa.R.C.P. 1910.16-5(b). Furthermore, the Court considered the propriety of an award of attorney’s fees to the obligee in this case. The Court concluded: (1) Rule 1910.16-3.1 did not render independent examination of the reasonable needs of the children by the fact-finder improper in high income cases; (2) a voluntary contribution to an irrevocable non-grantor trust for the benefit of the children was an inappropriate factor to consider for deviation purposes under Rule 1910.16-5(b); and (3) the obligee is not entitled to an award of attorney’s fees in this case.