Southern District Court of Appeals upholds increased amount of imputed income to father who opposed

Koch v. Koch, SD 35561, 2019 WL 3519706 (Mo. Ct. App. S. Dist. Aug. 2, 2019)

Form 14 is Missouri’s fundamental formula for determining the appropriate amount of child support in divorce/dissolution and parenting plan modification cases. Recently, in Koch v. Koch, the Southern District Court of Appeals upheld the Circuit Court of Camden County’s ruling which adjusted a divorced father’s child support obligation beyond what the parties’ had determined and asked for in the case.

More specifically, despite the divorced father’s arguments that he was not employable, the court applied the factors discussed in the comments to Form 14 and imputed $2,600/month ($15/hour) of income to father. The factors considered in these determinations include (1) the parent’s work history, (2) occupational qualifications, (3) employment potential, (4) job opportunities in the community, and (5) whether the parent is custodian for a child who has conditions impacting the parent’s employment status.



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