Swift v. Poitras
In a paternity case, the Sixth District affirmed the trial court's discretionary award of child support retroactive to the twins' birth but reversed the computation in five respects. Most notably, the court held it was an abuse of discretion to credit the father with 120 'overnights' for nights he spent as a non-rent-paying guest in the mother's home, and that child support guidelines worksheet figures (including tax deductions generated by child-support software) must each be supported by competent, substantial evidence.
Key facts
- Swift (mother) and Poitras (father) were parties to a paternity case involving twins; the trial court awarded child support retroactive to the twins' birth.
- The father argued he should receive credit for 120 overnights spent as a guest in the mother's home, and the trial court awarded child support using a guidelines worksheet that included tax deductions generated by child support software.
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Why it matters
The overnight-credit holding is a useful, transferable rule: a parent visiting and staying in the other parent's residence does not accrue timesharing overnights for guideline purposes, and the parties are not 'residing… — full analysis with a trial
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