Background
The Kentucky Cabinet for Health and Family Services filed a paternity complaint on behalf of K.L.G., alleging that J.T.P.W. was the biological father of a child born in January 2022 and seeking child and medical support. Court-ordered genetic testing showed a 99.9999998% probability of paternity.
After J.T.P.W. appeared in person for a March 17, 2026 hearing, the Jefferson Circuit Court imputed income to him at $17 per hour and calculated monthly child support of $553.41, including arrearages dating to the complaint’s filing. The court subsequently entered a judgment declaring him the child’s biological father, awarding the parents joint custody, and ordering support. Representing himself on appeal, J.T.P.W. challenged service, the availability of hearing recordings, and the evidentiary support for the imputed income and support calculation.
The Court’s Holding
The Kentucky Court of Appeals affirmed. It concluded that the record showed the Cabinet properly initiated the action under Kentucky’s paternity statutes, J.T.P.W. was properly served and summoned, he had an opportunity to retain counsel, and genetic testing established paternity to a high degree of certainty.
The court also held that J.T.P.W. had not demonstrated error in the support award. He appeared at the hearing where evidence was presented, including the statutory child-support worksheet, and the record did not establish that imputing income at $17 per hour was arbitrary, unreasonable, unfair, or unsupported by sound legal principles. His appellate brief identified grievances but did not develop persuasive, record-supported grounds for reversal.
Key Takeaways
- A party seeking reversal must identify specific errors and support the argument with the record and applicable law.
- The record supported the paternity judgment through genetic testing showing a 99.9999998% probability of paternity.
- The trial court did not abuse its discretion by imputing income at $17 per hour and ordering monthly child support of $553.41 plus arrearages.
Why It Matters
The opinion illustrates the deference Kentucky appellate courts give trial courts in child-support matters when their decisions remain within statutory parameters and are supported by the record. General assertions about service, missing recordings, or insufficient evidence will not justify reversal without developed argument showing how a specific error affected the judgment.