Darcy L. Howard v. Patrick S. White

Summary

The court held that an employer’s contribution toward an employee’s health insurance cannot automatically be added to gross income for child-support purposes. The party seeking inclusion must prove that the benefit is an in-kind payment that actually reduces the employee’s personal living expenses and must prove the amount of that reduction; the employer’s cost is not necessarily the benefit’s value. Because the record did not support attributing the full $14,000 employer contribution to White’s income, the court vacated and remanded for recalculation using annual gross income of $60,929.