Posted by Nydia Streets of Streets Law in Florida Child Support
What is a child support guidelines worksheet in Florida? This is a document which shows how child support was calculated in a case, including the parties’ net incomes, daycare expenses, health insurance expenses for the children and time-sharing percentage splits. This worksheet is required to be filed in a Florida family law case involving the establishment or modification of child support. This was an issue in the case Nepola v. Nepola, 4D2021-3316 (Fla. 4th DCA October 18, 2023).
In this case, the parties agreed on appeal that it was error for the trial court to not attach a child support guidelines worksheet or otherwise reference it in the case. This appellate opinion focused on explaining why it is not necessary, as held in prior cases, to attach the worksheet to the order. Instead the opinion explained that it is sufficient to file the worksheet as part of the case and reference it in the order.
The opinion explained “physical attachment of the worksheet is not necessary. Rather, the worksheet’s inclusion in the record is required. Rule 12.285(k), although cited by this court and the Second District for the ‘attachment’ requirement, does not contain any language indicating the guidelines worksheet must be physically attached to the order. If the parties comply with rule 12.285(k), and the trial court either files the guidelines worksheet with the order or indicates in the order that it relied on one of the submitted worksheets, then it is apparent how the trial court arrived at its determination of the child support, and there will typically be no impediment to review. If the trial court declines to approve any of the submitted proposed worksheets, and it adopts a modified version of a submitted worksheet, the party submitting the modified worksheet must ensure it is made a part of the record.”
The court concluded “To the extent our previous opinions could be read to announce a brightline rule that failure to physically attach the child support guidelines worksheet to an order requires reversal, we recede from those opinions.” Schedule your meeting with a Miami family law attorney to understand how the law may apply to the facts of your case.