Background
Alexis Harriman, Dillon Lamothe, and Tucker Rowland are the three legal parents of a child at the center of this support dispute. Harriman and Rowland are married, share a household, and have three other children together. After Rowland filed a complaint for parental rights and responsibilities in 2022, an Augusta District Court awarded all three parents shared parental rights and shared primary residence following hearings in March and April 2025.
Applying Maine’s child support guidelines for parents who provide substantially equal care, the District Court calculated a presumptive weekly support obligation of $22.62 owed by Lamothe to Harriman and Rowland. The court then deviated sharply upward from that figure, setting Lamothe’s weekly obligation at $196.04. It justified the deviation by finding that Harriman and Rowland’s three other children were “actually financially dependent” on them under 19-A M.R.S. § 2007(3)(K), and concluded that the adjustment mechanism in § 2006(5)(A) was inapplicable because the parents were co-primary care providers rather than a primary and nonprimary pair.
Lamothe moved for further findings of fact under M.R. Civ. P. 52(b), which the District Court denied. He then appealed, arguing the court abused its discretion by deviating so dramatically from the guideline amount without adequate findings.
The Court’s Holding
The Maine Supreme Judicial Court vacated the child support order and remanded for further proceedings. Writing for a five-member panel, Justice Connors held that the trial court committed reversible error by deviating from the presumptive child support guideline without first making the threshold finding—expressly required by § 2007(1)—that application of the guideline amount would be “inequitable or unjust.” That finding is not a formality; it is a prerequisite to any downward or upward deviation, and without it appellate review is impossible.
The court also identified a second potential error: the District Court’s conclusion that § 2006(5)(A)’s adjustment mechanism was unavailable simply because the parents share primary care. Relying on its recent decision in Waterman v. Wheeler, 2025 ME 96, the court reiterated that when parents provide substantially equal care, neither is the “primary residential care provider” for purposes of § 2006(5)(A), and therefore either may be entitled to an adjustment for dependent children in the household. Because the trial court calculated support as though the parents provide substantially equal care, its refusal to apply § 2006(5)(A) may itself have been error.
Because the District Court had denied Lamothe’s motion for further findings, the Law Court could not infer the missing findings from the record and was required to vacate. On remand, the court must determine whether the parents provide substantially equal care, apply § 2006(5)(A) if appropriate, and—if deviation from the guideline amount is still warranted—make an express finding that the presumptive amount would be inequitable or unjust.
Key Takeaways
- A Maine court cannot deviate from the presumptive child support guideline under § 2007 without an express finding that the guideline amount would be “inequitable or unjust”; that threshold determination is mandatory, not discretionary.
- When parents share substantially equal care of a child, neither qualifies as the “primary residential care provider” under § 2006(5)(A), meaning either parent may seek an adjustment for other dependent children living in the household.
- If a party timely moves for further findings under M.R. Civ. P. 52(b) and the trial court denies that motion, an appellate court cannot supply the missing findings from the record — making adequate written findings essential to preserving any deviation from the guidelines.
- A trial court’s failure to articulate the statutory basis and required threshold findings for a child support deviation is grounds for vacatur and remand, even where the underlying factual circumstances might have supported a deviation.
Why It Matters
This decision reinforces that Maine’s child support guidelines carry a strong presumption of correctness and that deviation requires more than identifying a relevant statutory factor — courts must connect that factor to an explicit finding of inequity or injustice. For practitioners, the case is a reminder to press for adequate written findings whenever the trial court departs from the guideline amount, and to file a Rule 52(b) motion to preserve the issue for appeal.
The opinion also extends the reach of Waterman v. Wheeler into multi-parent households, signaling that the equal-care adjustment mechanism of § 2006(5)(A) is available regardless of which parent has other dependents in the home. As three-parent families and shared-custody arrangements become more common in Maine litigation, this clarification of how the adjustment and deviation statutes interact will have practical significance beyond the unusual facts of this case.