Valentine v. Valentine
Decision Date | 08 December 2021 |
Docket Number | Docket No. 48254 |
Citation | 500 P.3d 514 |
Parties | Mandy L. VALENTINE, Petitioner-Appellant-Cross Respondent, v. Dan Merrill VALENTINE, Respondent-Cross Appellant. |
Court | Idaho Supreme Court |
Hall, Angell & Associates, Idaho Falls, for Appellant. Cory R. Stegelmeier argued.
Schreiner Law, Ammon, for Respondent. Gary L. Schreiner argued.
This case concerns the determination of a student parent's income for purposes of computing child support and the determination of parents’ respective pro rata shares of childcare expenses. Mandy Valentine ("Mandy") and Dan Valentine ("Dan") 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 this Court, Mandy challenges 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-appeals, challenging the district court's conclusion that the magistrate court abused its discretion in calculating his pro rata share of childcare expenses. For the reasons discussed below, we affirm in part, reverse in part, and remand for further proceedings.
Mandy and Dan1 divorced in May 2015. They share joint physical and legal custody of the two minor children from the marriage, with Mandy having primary physical custody. Shortly after the divorce, Mandy and the children moved to Moscow, Idaho, while Mandy attended the University of Idaho College of Law. At all times relevant to these proceedings, Dan has lived in Blackfoot, Idaho.2 Under the terms of the divorce decree, Dan is entitled to visitation totaling approximately twenty-eight percent of overnights each year. In addition, the decree provides that Dan is responsible for sixty-percent of "the school related child care [sic] costs [Mandy] incurs."
By all accounts, Mandy's and Dan's post-divorce relationship has been acrimonious. They have significant difficulty communicating with each other, and it appears they have never strictly followed the visitation provisions in the divorce decree, resulting in an ad hoc visitation schedule. Since their divorce, Dan has not availed himself of the full amount of his visitation time. In addition, Dan has not paid Mandy for any childcare costs.
In June 2017, Mandy filed a petition in magistrate court to modify the custody and support terms of the divorce decree.3 Additionally, as part of those proceedings, she filed a verified motion seeking to have Dan's unpaid share of the childcare costs reduced to a judgment. In her petition, Mandy claimed several substantial and material changes in circumstances justified modifying the decree, including Dan's inconsistent use of his visitation time and failure to pay his share of childcare costs. Dan filed a response and counterclaim, asserting that there had not been substantial and material changes in circumstances or, in the alternative, that the magistrate court should modify the custody schedule in the best interests of the children by limiting the "unrealistic demands" Mandy placed on him. In his response, Dan admitted to not paying his share of childcare costs, but asserted it was because Mandy did not provide him with proper invoices documenting that care, verification of her school-or-work-related need for childcare, or the amount of Idaho Child Care Program ("ICCP") benefits she received. Neither Dan nor Mandy requested the magistrate court determine whether Mandy was voluntarily underemployed.
The magistrate court considered Mandy's petition during a two-day bench trial in late December 2018. Pertinent to this appeal, the magistrate court received evidence concerning the various student loans, public assistance benefits, and wages Mandy received in the years following the divorce. The magistrate court also received evidence concerning Dan's increased income from a new job. Finally, Mandy presented evidence that the total childcare costs from June 2015 to June 2017 were $9,816.65 and contended that Dan's sixty-percent share of that amount was $5,889. Mandy's documentation of childcare expenses also showed that between August 2015 and April 2016, she received ICCP benefits for childcare costs totaling $3,938, which were paid directly to her childcare provider. Dan did not dispute that he owed Mandy some amount for childcare costs. However, he claimed he could not calculate how much he owed because Mandy's asserted costs did not account for the ICCP benefits she had received.
The magistrate court took the matter under advisement and subsequently issued a written order on March 21, 2019, addressing both the petition to modify and motion to reduce the unpaid childcare costs to a judgment. Then, ostensibly due to a typographical error in its order, the magistrate court issued amended findings of fact and conclusions of law on March 26. In its amended findings of fact and conclusions of law, the magistrate court concluded that Mandy's asserted bases for modifying the child custody order were attributable to the parties’ poor co-parenting skills, which were not permanent, material, and substantial changes in circumstances that justified a modification to the custody arrangements. However, the magistrate court concluded that there had been a substantial and material change in circumstances justifying modification of the child support order because both parties’ incomes had increased since the divorce. In reaching this conclusion, the magistrate court made factual findings as to each party's "Guidelines Income" pursuant to the Idaho Child Support Guidelines ("ICSG"). The magistrate court calculated Dan's Guidelines Income at $74,000 per year. Neither Dan nor Mandy challenge this finding. Next, the magistrate court determined that Mandy's Guidelines Income was $72,224 per year. It reached this figure by combining: (1) Mandy's wages from a part-time job; (2) the value of her section 8 housing assistance; (3) the amount of her yearly SNAP benefits; (4) a direct Stafford student loan; (5) a "graduate plus" student loan; and (6) "other income."4 Mandy's student loans accounted for $46,100 of her Guidelines Income. The magistrate court then used the parties’ new incomes to calculate a revised child support amount, setting Dan's child support obligation at $764.94 per month. Mandy had requested that Dan's child support obligation to be increased to $901 per month.
Turning to Mandy's motion for Dan's pro rata share of childcare costs to be reduced to a judgment, the magistrate court accepted Mandy's figure for childcare costs, finding that the total bill for the relevant time period was $9,816.65. Next, the magistrate court concluded that the ICCP benefits should be credited towards the total amount of the childcare expenses, not just to the portion attributable to Mandy. Accordingly, the magistrate court subtracted the amount of ICCP benefits ($3,938) from the overall cost ($9,816.65), and concluded that the amount of childcare costs subject to pro rata division between the parties was $5,878.65. Consequently, the magistrate court concluded that Dan's share of the unpaid childcare costs was $3,527.19, rather than the $5,889 Mandy requested he pay.
Mandy subsequently filed a motion for reconsideration, which the magistrate court denied. She then filed a notice of appeal to the district court. Sitting in its appellate capacity, the district court affirmed in part and reversed in part the magistrate court's order modifying the divorce decree. As to the issues raised before this Court, the district court ruled that the magistrate court did not abuse its discretion in modifying the child support order, but it did err in not making an explicit finding that Mandy was voluntarily underemployed before including her student loans in her Guidelines Income. However, the district court concluded such error was harmless because the clear language of the ICSG provided that both gross and potential income may be combined in arriving at a figure for Guidelines Income. Thus, Mandy's Guidelines Income would have been calculated the same even with a finding that she was voluntarily underemployed.
Next, concerning the magistrate court's order on the division of childcare costs, the district court concluded that the magistrate court abused its discretion. It reasoned that the magistrate court's order had the practical effect of allocating a portion of the ICCP benefits to Dan and only the Director of the Department of Health and Welfare had the authority to make and enforce rules regarding eligibility for those benefits. Accordingly, the district court found that the magistrate court abused its discretion because it had not cited any authority in support of its ruling and circumvented the administrative process for awarding ICCP benefits.
Mandy timely appealed, arguing that her student loans were improperly used in calculating her Guidelines Income. Dan cross-appealed, challenging the district court's conclusion that the Mandy's ICCP benefits could not be taken into account when calculating Dan's pro rata share of childcare costs.
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