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Beck v. Beck

Court of Special Appeals of Maryland

885 A.2d 887 (2005)

Relevant factsFree

Richard Beck (plaintiff) and Kimberly Beck (defendant) divorced in 2001, with Kimberly getting custody of their two children and Richard ordered to pay $608.45 per month in child support. Both had other children living with them, including a child Richard had after the divorce, for whom he separately paid $300 per month. In 2004, updated guidelines set Richard's support obligation at $816.17, but the circuit court reduced it to $700 based on Richard's obligation to a half-sibling in his household, while ruling that his fourth (post-divorce) child was irrelevant because deviations are only allowed for pre-existing child-support obligations. Kimberly appealed.

IssueFree

Whether a noncustodial parent is entitled to a downward departure from the statutory child-support guideline merely because of obligations to children from other relationships.

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