Background
Eddie Williams and Tayauna Mosley are the parents of P.E.M., born in 2017. Williams initially was not required to pay child support, but after a 2025 review, Child Support Services modified his obligation to $732 per month plus $263 per month in cash medical support.
CSS calculated Williams’s gross monthly income as $5,268.18 using irregularly dated and widely varying checks from his part-time work for his wife’s cleaning business. Although Williams reported being paid biweekly, CSS averaged the checks and treated the resulting amount as weekly income. The calculation also included a $1,500 check that Williams said reflected the sale of a vehicle rather than employment income.
Williams also sought qualified additional dependent deductions for two other children. One child was already covered by a support order. For the other, Williams had filed a voluntary paternity affidavit but presented no evidence that the state registrar had registered it. The district court adopted CSS’s calculations and declined to allow the additional deductions.
The Court’s Holding
The Iowa Court of Appeals affirmed the exclusion of both children from Williams’s qualified additional dependent deductions. Iowa Court Rule 9.8(2) barred a deduction for the child already covered by a prior support order. As to the other child, Rule 9.7 required both filing and registration of the paternity affidavit, and Williams did not provide evidence of registration.
The court reversed the income determination, concluding that CSS had improperly inflated Williams’s monthly income. The record showed monthly earnings between approximately $2,000 and $3,300, not $5,268.18. The court remanded with instructions to calculate Williams’s income on a biweekly basis and exclude the $1,500 vehicle-sale proceeds.
Key Takeaways
- A parent cannot claim a qualified additional dependent deduction for a child already covered by a prior court or administrative support order.
- Merely filing a paternity affidavit does not establish eligibility for the deduction; the affidavit must also be registered by the state registrar.
- A child-support income calculation must reflect the parent’s actual pay frequency and exclude nonemployment proceeds such as money from a vehicle sale.
Why It Matters
The decision underscores that parents seeking additional-dependent deductions must satisfy the guidelines’ specific proof requirements. A claimed parental obligation is insufficient when the required court order, admission, registered affidavit, or marital presumption is not established.
It also shows that uncertainty caused by irregular earnings does not permit reliance on a demonstrably inflated income figure. Courts must account for the actual pay period and remove transactions that are not employment income when calculating support.