Bolds v. Strong

Beatrice Bolds and the Department of Revenue appeal an order modifying Freddie Strong’s child support obligation because the amount specified deviated from the guidelines by more than five percent. We approve the trial court’s decision to increase child support. But we reverse the trial court’s award of less than the guideline amount because the reasons given for deviation are insufficient as a matter of law.

After Mr. Strong stipulated that he was the natural father of Ms. Bolds’s oldest child, child support was ordered at $42 per month in 1981. In 1983, after a second child was born, child…