Michael Hanrahan, Appellant v. Jeanne Bakker, Appellee

Summary

The Court held that high-income child-support awards require a separate examination of the children's reasonable needs during the third step of the guideline calculation, using the deviation factors and required income and expense statements. It held that a parent's voluntary contribution to an irrevocable trust for the children cannot justify reducing the parent's support obligation, and that Mother was not entitled to attorney's fees under the parties' agreement. The Court vacated the lower courts' orders and remanded for further proceedings. Justice Wecht, concurring, agreed with the result but would locate the reasonable-needs inquiry specifically in the standard-of-living deviation factor.