Betty Berryhill v. Charles Thomas Rhodes

Summary

The court held that an unapproved private agreement cannot establish or permanently limit a parent's child-support obligation because it conflicts with the statutory scheme and Child Support Guidelines. It remanded for calculation of support under the Guidelines, consideration of any justified deviation, and determination of the appropriate income-averaging period, while crediting payments already made. Justice Birch, joined by Justice Barker, concurred in the remand but would have treated private agreements as permissible subject to judicial review and modification.