Department of Revenue v. Skirko

The Department of Revenue (DOR), on behalf of Richard Skirko, appeals an order denying its petition to increase child support. DOR argues that the trial court erred in deviating from child support guidelines without written reasons or record support. We reverse.

Joanne and Richard Skirko were divorced in 1995. Mr. Skirko was awarded custody of their son but was not awarded child support because of Mrs. Skirko’s lack of ability to pay. In 1999, a Dade County circuit court modified the final judgment, awarding Mr. Skirko $200 a month in child support. In 2001, DOR, on behalf of Mr. Skirko,…