Ghidotti v. Barber

Summary

The Court held that a parent whose only income is means-tested public assistance may not have income imputed for child-support purposes under the child-support formula unless the trial court properly finds that applying the formula would be unjust or inappropriate. The trial court failed to evaluate the required factors and failed to make the findings necessary to justify deviation from the formula, so the Court reversed and remanded for a new support calculation. Justice Boyle, dissenting, would have upheld the imputation because the parent had a voluntary unexercised ability to earn and the lower courts had satisfied the applicable requirements.