Donahue v. Getman

After divorcing Richard Getman (defendant), Virginia Getman Donahue (plaintiff) was later awarded sole custody of their three children but initially denied child support based on Richard's limited means. When Virginia later sought guideline-based support given Richard's disability and social security income, the trial court awarded far less than the guidelines specified, citing Richard's total disability, medical expenses, and the needs of his new stepchildren, but never addressed Virginia's own financial condition or several other statutory factors. Virginia appealed, arguing the trial court abused its discretion by deviating from the guidelines without making the required findings on every relevant factor.