Carson Waterman v. Grady Wheeler

Waterman, 2025 ME 96 (Supreme Judicial Court of Maine 2025) · Supreme Judicial Court of Maine · December 4, 2025 · No. Yor-25-174

Summary

The Maine Supreme Judicial Court held that when parents provide substantially equal care, neither parent is the primary care provider for purposes of 19-A M.R.S. § 2006(5)(A). Accordingly, a parent who is legally obligated to support another child is entitled to a child-support adjustment, and the court vacated the support order and remanded for recalculation.

Holdings

  1. When parents provide substantially equal care, neither parent is the primary care provider for purposes of 19-A M.R.S. § 2006(5)(A). Accordingly, either parent may qualify as a parent who is not the primary care provider and may receive the statutory adjustment if legally obligated to support another child.

Questions Presented

  1. Whether a parent who provides substantially equal care with the other parent may obtain the child-support adjustment under 19-A M.R.S. § 2006(5)(A) for a legal obligation to support another child in that parent's household.

Disposition

vacated

Cases Cited (4)

  • McCarthy v. Guber, 2023 ME 53, ¶ 10, 300 A.3d 804(followed)
  • Johnson v. Smith, 1999 ME 168, ¶ 6, 740 A.2d 579(followed)
  • Cent. Me. Power Co. v. Chevereux Marine, Inc., 2013 ME 37, ¶ 8, 68 A.3d 1262(followed)
  • Sutherland v. Morrill, 2008 ME 6, ¶ 6, 940 A.2d 192(followed)

Cited In (0)

No citing cases on record yet.

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