In the Matter of Steven D. Rose, as Commissioner of the Oswego County Department of Social Services

Summary

The Court of Appeals affirmed the order upholding a zero-dollar child-support obligation for an indigent noncustodial mother whose only income was public assistance. It held that the State's irrebuttable $25 monthly minimum conflicted with federal law requiring a rebuttable presumption that guideline-based support is correct, including an opportunity to reduce the obligation to zero when inability to pay is shown. The court also rejected the appellants' claim that the lower court abused its discretion.