Rose on Behalf of Clancy v. Moody

A mother with no income, entirely dependent on social services, had custody of two of her three children while the grandmother had custody of the third; the county's social-services department (DSS) sought to compel the mother to pay New York's statutory minimum $25 per month in child support to the grandmother. The Federal Child Support Enforcement Act required state guidelines to create only a rebuttable presumption that the guideline amount was correct, allowing that presumption to be defeated by a showing the amount was unjust or inappropriate. The family court found the mother's income was $0 and the appropriate support amount was $0, and the appellate court found the federal Act preempted the state's $25 minimum; DSS appealed, arguing the minimum should still apply "to send a uniform public policy message" even though it wouldn't actually be collected.