In re the Marriage of Fairchild

¶[1 An obligor parent is entitled to reimbursement for certain expenses not actually incurred by the obligee parent. RCW 26.19.080(3). In this case, a superior court judge reversed a commissioner’s reimbursement order, concluding Janis Davis, formerly known as Janis Fairchild, satisfied her burden of proof in showing day care and medical expenses were incurred. Her former husband, Daniel Fairchild, appeals, contending the burden of proof requires more than just a declaration that expenses were paid. We agree and reverse and remand.

FACTS

¶2 Mr. Fairchild and Ms. Davis have two daughters; one…