In high income child support cases (high income is defined by law as cases in which the net incomes of the parties combined exceeds $30,000.00 per month), in order to avoid unduly large support results, the Trial Court must consider the “reasonable needs” of the child or children. This ruling resulted in the case Hanrahan v. Bakker, a 2018 Pennsylvania Supreme Court opinion.
Child Support in Pennsylvania is calculated pursuant to the Pennsylvania Support Guidelines. Prior to this ruling, with certain exceptions, the general rule was that formula was used in order to arrive at the support amount to be paid by a parent. This “mechanical” methodology, in high income cases, sometimes resulted in child support numbers that appeared to have no reasonable relationship to the actual needs of the child or children in a particular case. However, before Hanrahan, this “reasonable needs analysis” was not required.
Justice Max Bear, writing for the majority in this case, stated that in high income cases, the Trial Court should consider the particular children’s reasonable needs in applying that Rule to arrive at appropriate support awards in high income support cases.
In making this analysis, the Court must state the specific facts the Trial Court relied upon in making its decision. This will force the Court to closely look at the actual needs of the child or children in deciding how much money is actually necessary in a high income case.
Specifically, in Hanrahan, by only using the child support guidelines as was required at that time, a monthly child support award of $59,200.00 was entered against the Father in that case. The Father had written to Mother before this matter went to court saying that he had a large increase in salary and the strict application of the guidelines resulted in an award of child support that will “…yield a result that is way beyond any realistic estimate of the reasonable needs of the children” and offered to continue paying $7,851.00 per month, which he had paid during the previous year. Mother did not agree.
It should be noted that prior to the passage of the Guidelines calculations in Pennsylvania, the Court did a reasonable needs analysis in high income cases. This resulted in wildly different Support awards in cases of similar income. Because of the inconsistency of these awards, the Guidelines were instituted to try to arrive at some uniformity of process in fashioning these awards. Hanrahan appears to be a blending of these two procedures. While the Guidelines analysis is still to be done under Hanrahan, included in that process is the needs based analysis previously required as an apparent “check and balance” against unreasonable high awards as a result of a strict application of the Guidelines.