O'Roake v. State, ex rel. Department of Family Services
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The Supreme Court reversed the child support order requiring Father to pay post-majority support for his child, Zao, while Zao was attending college, holding that the district court abused its discretion when it ordered post-majority support.
At issue was the second motion to modify support filed by the Department of Family Services, Child Support Enforcement Division. The trial court found that Zao suffered from phenylketonuria, a metabolic disorder that required a special diet and rendered Zao disabled and incapable of self-support. The court then ordered Father to continue paying support of $375 per month after high school as long as Zao was enrolled in full-time college. The Supreme Court reversed, holding that the district court's findings were unsupported by the evidence.
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