Courtney L. Schwartz v. Jodi S. Heeter

RUSH, Justice.

Irregular income — bonuses, commissions, and the like — can make applying the Child Support Rules and Guidelines challenging. Practitioners and courts have worked to craft suitable solutions, and we certainly encourage parents to negotiate creative agreements that accurately account for irregular income, avoid litigation, and adequately provide for children. Here, in an effort to craft a workable solution, Mother and Father made a seemingly simple agreement: to recalculate their support obligation annually using the Guidelines.

But despite their best-laid plans, their agreement…