Carol M. Westgate, Nka Carol Kemm, Appellant v. Murray Westgate, Respondent

Summary

The court held that a parent’s failure to comply with visitation arrangements cannot justify reducing child support or refusing to reduce support arrearages to judgment. Applying the statutory guidelines, it reversed the family court’s judgment and remanded for adoption of the referee’s recommended support amount and reconsideration of arrearages under permissible equitable factors. The court also rejected reliance on pre-guideline authority to the extent it supported punishment through child support.