Howard v. White
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Patrick S. White appealed a judgment from the District Court in Lewiston, Maine, which determined parental rights and responsibilities concerning his minor child with Darcy L. Howard. The main issue on appeal was whether the court erred by including the cost of White's employer-provided health insurance in his gross income when calculating his child support obligation. The Maine Supreme Judicial Court agreed with White that this inclusion was erroneous.
The court explained that under Maine law, gross income for child support calculations includes in-kind payments received by a parent if they reduce the parent's personal living expenses. However, the court clarified that the burden is on the party seeking to include the value of such a benefit to prove that it actually reduces the other parent's personal living expenses and the amount of that reduction. In this case, Howard did not provide evidence showing that White's receipt of health insurance from his employer reduced his personal living expenses by the full cost of the insurance to his employer. The court concluded that it is the value to the employee, not the cost to the employer, that matters for purposes of determining gross income for child support calculations.
As a result, the Maine Supreme Judicial Court vacated the judgment and remanded the case for further proceedings to recalculate White's child support obligation based on his gross income without the inclusion of his employer's cost of providing health insurance.
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