Upon the Petition of DeAngelo Delonn Seay and Concerning Andrea Lynette Thomas

Summary

The Iowa Supreme Court held that Iowa Court Rule 9.14 requires use of the offset method to calculate child support in cases where the parties are awarded joint physical care, even when their residential time is not mathematically equal. The court vacated the court of appeals decision and district court judgment and remanded for recalculation of child support and reconsideration of medical expenses and tax-dependency allocations.

Holdings

1. Iowa Court Rule 9.14 applies whenever the district court awards joint physical care, even when the residential schedule is not mathematically equal.
2. The applicability of Iowa Court Rule 9.14 turns on whether the court awarded joint physical care, rather than on the number of residential days alone.
3. The child-support amount calculated under Rule 9.14 is presumptively valid but may be varied if the district court makes written findings that applying the guidelines would be unjust or inappropriate under the established criteria.
4. On remand, the district court must reconsider the medical-support provisions and the allocation of the children as tax dependents because those provisions were based on the erroneous child-support calculation.
5. Thomas was not awarded appellate attorney fees.

Questions Presented

1. Whether Iowa Court Rule 9.14 requires use of the offset method to calculate child support when a court awards joint physical care but one parent has somewhat more residential time than the other.
2. Whether the child-support amount calculated under the offset method may be varied from the guideline amount based on written findings that application of the guidelines would be unjust or inappropriate.
3. Whether the district court should reconsider medical-expense allocations and tax-dependent allocations because they were based on an erroneous interpretation of the child-support guidelines.
4. Whether Thomas was entitled to an award of appellate attorney fees.

Disposition

reversed_and_remanded