In re Barrett
Supreme Court of New Hampshire
841 A.2d 74 (2004)
Susan Barrett (plaintiff) and John Coyne (defendant) divorced with Barrett receiving primary custody of their daughters. After moving to New Hampshire, Barrett enrolled their daughter Kathryn in a private school for a more structured learning environment; Coyne, whose financial information was submitted for a financial-aid application that was denied, refused to help with tuition when Barrett later asked. The trial court initially found Coyne unable to pay, but on reconsideration included his current wife's income and ordered him to pay $8,000 toward tuition. Coyne appealed.
Whether a court may order a parent to pay private secondary-education expenses beyond the child-support guidelines if special circumstances warrant the award.