Alexis Harriman v. Dillon Lamothe

Summary

The Maine Supreme Judicial Court vacated a child support order requiring Dillon Lamothe to pay $196.04 per week, rather than the presumptive guideline amount of $22.62. The court held that the trial court failed to find that applying the guideline amount would be inequitable or unjust, and that the absence of required findings prevented appellate review. The case was remanded for further findings and proceedings concerning the child support calculation and any applicable adjustment or deviation.

Holdings

1. A court may not deviate from the presumptive child-support guidelines unless it expressly finds that applying the guideline amount would be inequitable or unjust. Because the District Court made no such finding, its deviation was legally insufficient.
2. When parents provide substantially equal care, neither parent is the primary residential care provider for purposes of 19-A M.R.S. § 2006(5)(A), and either parent may be allowed the statutory adjustment for another legally supported child in the household. The District Court's conclusion that the adjustment was categorically unavailable because the parents were co-primary care providers was therefore not necessarily correct.
3. When a trial court denies a timely motion for further findings under Maine Rule of Civil Procedure 52(b), the appellate court may not attribute findings or conclusions to the trial court beyond those explicitly stated in the judgment. If the judgment lacks findings sufficient to support the result, appellate review is impossible.

Questions Presented

1. Whether the District Court could deviate from the presumptive child-support guideline amount without finding that application of the guideline amount would be inequitable or unjust.
2. Whether, when parents provide substantially equal care, the adjustment for a parent legally obligated to support another child in the household may apply even though neither parent is the primary residential care provider.
3. Whether the District Court's denial of Lamothe's Rule 52(b) motion permitted the appellate court to infer findings not expressly stated in the judgment.

Disposition

vacated