Background
Father sought a paternity, custody, and support judgment concerning three children. By trial, one child was emancipated. The circuit court awarded the parents joint physical custody of the two remaining minor children: one lived primarily with Mother with Father receiving alternating-weekend custody, while the other alternated residences weekly.
Neither parent submitted a Form 14 child-support calculation. The trial court prepared two Form 14s, one reflecting each child’s residential arrangement, but calculated each as if it covered two children and designated Father as the paying parent on both. After finding the calculations unjust and inappropriate, the court averaged them and ordered Father to pay Mother $310 per month, retroactive to October 2023.
The Court’s Holding
The Missouri Court of Appeals affirmed. Father argued that the circuit court should have used the required split-custody Form 14 method and should not have designated him as the paying parent for the child who resided equally with both parents.
The court did not reach those claimed calculation errors. A party challenging a child-support calculation must submit a completed Form 14 to the trial court to preserve the issue for appeal. Because Father submitted none, his claims were unpreserved. His arguments could therefore be considered only for plain error, but he did not request plain-error review.
Key Takeaways
- A party must file a completed Form 14 to preserve a challenge to a child-support calculation.
- Even where the trial court prepares its own Form 14, a party who submitted no Form 14 cannot obtain ordinary appellate review of alleged calculation errors.
- An appellate court will not conduct plain-error review sua sponte when the appellant does not request it.
Why It Matters
The decision reinforces that Form 14 is not merely a calculation aid; it is essential to preserving child-support disputes for appeal in Missouri. Counsel challenging a proposed support amount should submit a completed calculation reflecting the asserted methodology and party designations.