Amanda M. Vogus v. Eric L. Vogus

Summary

The Alaska Supreme Court vacated a child support order that imputed substantially higher income to Amanda Vogus than her prior massage-therapy earnings supported. The superior court could rely on her prior earnings as prima facie evidence of earning capacity, but it needed specific findings about her qualifications, work history, and available employment before increasing both her hourly rate and weekly hours. The court also directed the superior court to reconsider whether the support order was improperly made retroactive to a period when the parties still operated under shared custody.