In computing a parent’s child support obligation where that parent has remarried, it is error for the Court to use a new spouse’s contributions to inflate the income of the remarried parent under the theory of in kind payments.
Part of opinion: In computing a parent’s child support obligation where that parent has remarried, it is error to use a new spouse’s contributions to inflate the income of the remarried parent. See Hilbrands v. Hilbrands, 320 So. 3d 938, 940 (Fla. 2d DCA 2021) (“[I]t is error to impute additional income to a party based on ‘in-kind contribution[s]’ from a new spouse.”); Hinton, 725 So. 2d at 1158 (“The effect of a former spouse’s remarriage to a new spouse who can contribute to expenses may be an increase in the former spouse’s disposable income after he or she pays child support obligations, but it plays no role in calculating child support.”); see also Hanley v. Hanley, 734 So. 2d 529, 530–31 (Fla. 4th DCA 1999) (citing favorably to Hinton).
Court: 4th DCA
Case No. 4D21-1731
Case Name: Crystal Nadeau v. Henry Reeves
Opinion date: October 20, 2021
Link to full opinion: https://hi.switchy.io/7EIx