Schneider v. Almgren
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Jeffrey Almgren and Carol Schneider divorced in Nebraska and Schneider moved to Washington with the couple's two children. The decree of dissolution set child support to continue during each child's minority. In Nebraska, the age of majority is 19 years. The Nebraska court modified the decree, approving the mother's move and adjusting certain obligations. Neither modification changed the duration of the father's child support obligation. The mother registered and moved to modify the Nebraska decree in Asotin County under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The Asotin County Superior Court entered an order of child support stating that the obligation would terminate when the children reach 18 or graduate from high school, whichever occurs last, and reserving the right to request postsecondary support. The order was entered without objection by the father regarding the application of the Uniform Interstate Family Support Act or a challenge to the trial court’s jurisdiction to modify the Nebraska child support order. The mother later petitioned for postsecondary educational support for their daughter. The father filed a cross-motion to modify child support due to his recent job loss. The trial court granted the mother's motion for postsecondary educational support and denied the father's motion for a downward modification. The father moved for reconsideration, raising for the first time the issue of the trial court’s authority under the UIFSA to enter orders extending child support for his daughter beyond the age of majority in Nebraska, which was denied. Upon review, the Supreme Court held that the superior court erred by extending the father's child support obligation by granting postsecondary support for the daughter to attend college. The Supreme Court reversed the Court of Appeals, which affirmed the trial court, and remanded the case for further proceedings.
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