Roman v. Roman
The Sixth DCA held that regular payments of a parent's household bills (mortgage, utilities, HOA fees) by her boyfriend and his mother are 'in kind payments' that must be included in gross income under section 61.30(2)(a)13., Florida Statutes. The trial court erred in reading Nadeau v. Reeves to limit that subsection to employer-provided in-kind benefits; the court reversed and remanded to recalculate child support including those imputed amounts.
Key facts
- Roman sought child support modification; the trial court excluded regular payments by the mother's boyfriend and his mother for her mortgage, utilities, and HOA fees from the mother's gross income in calculating child support.
- The mother argued that section 61.30(2)(a)13.'s 'in kind payments' applied only to employer-provided benefits, relying on Nadeau v. Reeves; the trial court agreed and did not impute those household expense payments as income.
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Why it matters
This is the Sixth District's first holding construing section 61.30(2)(a)13., and it squarely rejects the argument (drawn from Nadeau and Hinton) that in-kind income is limited to employer-furnished benefits. Family… — full analysis with a trial
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