Footnotes for ‘If They Can Do Parenting Plans, They Can Do Child Support Plans’

These are the footnotes for the article If They Can Do Parenting Plans, They Can Do Child Support Plans by Stephen Erickson

[1].    Seeinfra Part II.C.

[2].    The
first use of the checkbook procedure was by Erickson Mediation Institute in
1981.  Following the success of the procedure, Erickson reported his findings
in 1988.  Stephen K. Erickson, The Legal Dimension of Divorce Mediation,
inDivorce Mediation Theory and Practice 108, 105-24 (Jay Folberg & Ann Milne eds., 1988) [hereinafter The Legal
Dimension
]. See alsoStephen
K. Erickson & Marilyn S. McKnight,Mediating
Divorce, A Step-by-Step Manual (1998).  Parents first create a budget of
expenses incurred on behalf of the children (most often with the help of a
mediator) and they determine which expenses are to be shared, such as clothing,
uncovered medical and other expenses and which expenses are paid independently
by each parent without sharing the costs, such as vacation, travel, recreation
and food and eating out.  The Legal Dimension,supra,
at 112.  Parents use a joint checking account or joint debit card to pay the
shared expenses and each parent may contribute to this account equally or on a
pro rata, proportional basis according to their gross or net incomes.  Id. at 113.

[3].    Seeinfra Part II.B.

[4].    See infra Part II.B.

[5].    Seeinfra Part II.C.

[6].    Seeinfra Part II.C.

[7].    See infra Part III.

[8].    SeeMinn.
Stat. § 518.1705 (2004). (detailing the statutory
requirements for the proper implementation of a parenting plan).  Parenting
plans change the focus away from the adversarial “all or nothing” question of
custody and who was the most fit or unfit in the past.  The process
refocuses on the more easily answered question of what future parenting
arrangements can be established that will allow both divorcing parents to
remain significant and involved with their children.  The goal of the Minnesota
Parenting Plan Act, as stated by its chief author Rep. Andy Dawkins is
fivefold: “1) to reduce the number of costly legal battles in custody and
visitation proceedings; 2) to eliminate the deep wounds that result from
custody and visitation litigation; 3) to improve the future relations between
the parties; 4) to maximize the involvement of both parents; and 5) to create
healthier families.”  Peter V. Rother, Balancing Custody Issues: Minnesota’s
New Parenting Plan Statute
, 57Bench
& B. Minn. 27, 27 (2000) (citing Parenting Plans: Hearing on H.F.
3311 Before the H. Civil Law Comm.,
2000 Leg., 81st Reg. Sess. (Minn. 2000)
(statement of Andy Dawkins, Member, House Civil Law Committee)).

[9].    See infra Part IV.

[10].    “Flexibility
is particularly attractive in custody disputes because mediation allows 
parents to design parenting plans that more accurately address their lifestyles,
work schedules, and unique family dynamics, than would a rigid custody plan 
ordered by a judge.  A process that promotes a solution well suited to the
litigants’ interests is more likely to increase the participants’ perception of
fairness of the process . . . ” Alexandria Zylstra, The Road From Voluntary
Mediation to Mandatory Good Faith Requirements: A Road Best Left Untraveled
,
17J. Am. Acad. Matrim. Law. 69,
73 (2001).

[11].    See Chief Justice Robert A. Mulligan’s
Announcement Regarding the Child Support Guidelines,
http://www.mass.gov/courts/cjamcsg2006.html (last visited January 16, 2006)
(“Any Guidelines which may be promulgated will invariably spawn criticism, but
I believe that it is essential that we conduct an in-depth analysis.”).

[12].    “The
primary goal of moving from a ‘percent of obligor’ child support system to an
‘income shares’ model is to create more fair and equitable child support
guidelines.  Testimony before the legislature and hundreds of anecdotal
submissions to the chief author suggested that the present system is perceived
to be unfair to obligors.”  Senator Tom Neuville, The New Income Shares
Model for Calculating Child Support in Minnesota
, 15Fam. L. F. (Minn. St. B. Ass’n) 4, 4
(Winter 2006).

[13].    Id. “A fourth goal of the new guideline is to simplify
the calculation of child support . . . . [by] [c]alculating support based upon
gross income rather than net income [and] [c]reating a web-based child support
calculator to help calculate support, parenting expense credits, and self
support reserves.” Id.

[14].    “Yet,
despite harsh penalties and a billion-dollar budget devoted to child support
enforcement, compliance rates are still relatively low.”  Solangel Maldonado, Beyond
Economic Fatherhood: Encouraging Divorced Fathers to Parent
, 153U. Pa. L. Rev. 921, 961 (2005) (citingBureau of the Census, U.S. Dep’t of Comm., Child Support: 1999 tbl.4 (2000)).

[15].    See Marygold S. Melli, Guideline Review:
Child Support and Time Sharing by Parents
, 33 Fam. L.Q. 219, 225 (1999); Seealso Laura W.
Morgan, Child Support Guidelines and the Shared Custody Dilemma, Divorce
Litigation (Nov. 1998), available at http://www.childsupportguidelines.com/articles/art199906.html
(exploring alternate theories of child support calculation).

[16].    Laura W. Morgan, The
Constitutionality of Child Support Guidelines Redux
(June 2003),
http://www.supportguidelines.com/articles/art200306.html.

[17].    Alabama, Arizona,
California, Colorado, Connecticut, Florida,
Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Michigan,
Missouri, Nebraska, New Jersey, New Mexico, North Carolina, Ohio, Oklahoma,
Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Utah,
Vermont, Virginia, Washington, West Virginia, Wyoming all use the Income Shares
model.  Jane C. Venohr & Robert G. Williams, The Implementation and Periodic
Review of State Child Support Guidelines
, 33 Fam. L.Q. 7, 10-11 (Spring 1999).

[18].    Alaska,
Arkansas, Georgia, Illinois, Minnesota, Mississippi, Nevada, New Hampshire, New
York, North Dakota, Tennessee, Texas, Wisconsin all use the Percentage of
Obligor model, and the District of Columbia and Massachusetts use a Percentage
of Obligor Hybrid model that is similar. Id.

[19].    Id.See also Paula Woodland Faerber, Empirical Study: A Guide to the Guidelines: A Longitudinal Study of Child
Support Guidelines in the United States
, 1 J.L. & Fam. Stud.
151, 157-60 (1999) (explaining various methods of determining child support
obligations, including the Melson formula).

[20].    Faerber, supra note 19, at 158.

[21].    See id.

[22].    See Minn.
Stat. § 518A.35
subdiv. 2 (2004).  See alsoMartin
L. Swaden & Linda A. Olup, 14 Minnesota Practice: FamilyLaw §
7.7 (2nd ed. 2006) (explaining the calculation of child support in Minnesota as of January 1, 2007).

[23].    Neuville, supra note 12, at 5.

[24].    See Linda D. Elrod & Robert G. Spector, A
Review of the Year in Family Law: Parentage and Assisted Reproduction Problems
Take Center Stage
, 39Fam. L.Q. 919, chart 3 (Winter 2006), available at 
www.abanet.org/family/familylaw/FLQchildsupport06.pdf.

[25].    Family
Support Act of 1988, Pub. L. No. 100-485, 102 Stat. 2343, (1988).

[26].    See Faerber, supra note 19, at 159-60.

[27].    See Del.
Fam. Ct. R. 52(c); Haw. Rev.
Stat. Ann. § 576D-7 (LexisNexis 2006); Mont. Code. Ann. § 40-6-116 (2006).  See also Faerber, supra note 19, at 158.

[28].    45 C.F.R. § 302.56
(2000).

[29].    See Faerber, supra note 19, at 152.

[30].    See id.  As Faerber explains:


Child support guidelines create a rebuttable presumption that the amount of the award under the
guidelines is the correct amount of child support. While each state has established
separate guidelines, the guidelines provide only a starting point for
determining child support. Each state has also created methods and reasons for
deviating from the guidelines. The deviations are based on items such as
financial needs and resources of the child, financial needs and resources of
the custodial parent, standard of living if the marriage had remained intact,
physical and emotion [sic] condition of the child, financial needs and resources
of the non-custodial parent, excessive or abnormal expenditures, concealment or
fraudulent disposition of property, length of visitation and associated expenses.
The most flexible of the deviations allows a court to deviate on the basis of
fairness to the parties and other equitable principles.


Id.

[31].    In
Minnesota, the new income shares child support formula calls for no payment
of child support to either parent if the parenting time is equal and the
parental incomes for child support is also equal.  See generally Michael
McNabb & Diane Anderson, How to Calculate the Child Support Obligation
With the New Income Shares Model
,Fam.
L.F., Winter 2006, at 13.

[32].    Family
Support Act of 1988, Pub. L. No. 100-485, 102 Stat. 2343, (1988).

[33].    Id.; See 45 C.F.R. § 302.56 (2000).

[34].    Family Support Act of
1988, Pub. L. No. 100-485, § 101, 102 Stat. 2343, 2344-45 (1988).

[35].    See Rother,supra note8, at 30 (explainingtestimony of Andy Dawkins about intent and
expectations of Minnesota Parenting Plan legislation).

[36].    See 45 C.F.R. § 302.56 (2000).

[37].    See Jo Michelle Beld, Improving
Child Support Guidelines in Minnesota: The “Shared Responsibility” Model for
the Determination of Child Support
, 28 Wm. Mitchell L.Rev. 791, 848-53 (2001) [hereinafter Improving
Child Support Guidelines in Minnesota
].  See also Jo Michelle Beld, Revisiting
“The Politics of Fatherhood”: Administrative Agencies, Family Life, and Public
Policy
,36Pol.Sci. & Pol. 713, 716-17 (2003) [hereinafter Revisiting “The
Politics of Fatherhood”
].

[38].    Improving Child Support Guidelines
in Minnesota
, supra note 37, at 849.  See also Ira Mark Ellman, Fudging Failure: The
Economic Analysis Used to Construct Child Support Guidelines
U. Chi. Legal F. 167, 168 (2004).

[39].    In
1983, Minnesota adopted a formula that originated in Wayne County, Michigan,
and was brought to Minnesota by a group of Family Court Referees attending a conference
there.  In an  interview with William Haugh a former Ramsey County Family Court
Referee who attended that conference, Mr Haugh stated it was his  recollection
that  the guidelines formula Minnesota adopted  in 1983  first in three
metropolitan counties by court rule and then later statewide, was based upon a
retrospective averaging of Wayne County Michigan judge’s child support rulings
over a six-month period of time in the late ’60s or early 70’s.  Interview with
the late William E. Haugh, Jr., Partner, Collins, Buckley, Sauntry, &
Haugh, Attorneys at Law, in Minneapolis, Minn. (Dec. 2002) [hereinafter
Interview with William  E. Haugh].

[40].    Id.

[41].    Seesupra Part II.A.

[42].    See generally Scott Altman, Lurking in the Shadows,
68S. Cal. L. Rev. 493 (1995) (discussing the problem of trading days for dollars).

[43].    See Laura Wish
Morgan, The Custodial Parent’s Duty to Account to the Non-custodial Parent
for how Child Support Money is Spent
(April 2000), at
http://www.childsupportguidelines.com/articles/art200004.html.

[44].   See Family Support Act of
1988 § 101, 42 U.S.C. § 666(b)(3)(A) (2000).

[45].    Valento
v. Valento 385 N.W.2d 860, 862-63 (Minn. Ct. App. 1986) (noting that a party’s
support obligation is determined by his or her guideline amount for the period
of time the other parent has custody).

[46].    Minn. Stat. § 518.36 subdiv. 2 (2004).

[47].    Id.

[48].    Telephone
interview with Michael McNabb, Partner, Michael McNabb Law Office, in Burnsville, Minn. (Jan. 2 & 25, 2007).

[49].    See generally Altman, supra note 42 (discussing
parties trading custody or visitation time for child support).

[50].    Family
Support Act of 1988, Pub. L. No. 100-485, 102 Stat. 2343, (1988).

[51].    Jane
C. Murphy, Legal Images of Fatherhood: Welfare Reform, Child Support
Enforcement, and Fatherless Children
, 81Notre
Dame L. Rev. 325, 350-51 (2005).  “Over the last three decades, then,
both the federal and state governments have constructed massive bureaucracies
focused on making non-custodial parents – mostly low-income fathers – pay child
support.”  Id. at 350.

[U]nder the
child support distribution scheme for families on welfare, the custodial parent
assigns her right to support and the state retains support paid by
non-custodial parents as reimbursement for welfare benefits. Thus, the
ever-increasing resources devoted to collect child support from low-income
fathers have no direct impact on the financial well being of children on
welfare.

Id. at 352 (footnote omitted).

[52].    Black’s Law
Dictionary 257 (8th ed.
2004).

[53].    See Rother, supra note 8.

[54].    See generally Carol Rogerson, Child Support Under
the Guidelines in Cases of Split and Shared Custody
, 15Can. J. Fam. L. 11, 20-33 (1998) (discussing the difficulties of accounting for money spent while
with the children).

[55].    See, e.g., Mo. R. Civ. P.
Form 14.  One state, Missouri, has recognized the costs contributed by
the non-custodial visiting parent by reducing the child support payments for
the non-custodial parents who consistently exercises visitation privileges.  Id.

[56].    Seegenerally Rother, supra note 8,
at 27-28. (citing Parenting Plans: Hearing on H.F. 3311 Before the H. Civil
Law Comm.,
2000 Leg., 81st Reg. Sess. (Minn. 2000) (statement of Andy
Dawkins, Member, House Civil Law Committee)).

The legal
adversarial system asks, “Who will be awarded custody of the minor children?”
The result is that the parent who is not awarded custody is then labeled a
non-custodial, visiting parent.  The only other place we use the word “custody”
is with prisoners. The only other place in our language that we use the word
“visitation” is at the funeral parlors. Creating parenting plans teaches people
cooperation. It is not necessary for them to be cooperative in the first
place.  After all, they are getting divorced.

Interview with
Marilyn McKnight, President-Elect of Association for Conflict Resolution and
Family Mediator, Erickson Mediation Institute, in Minneapolis, Minn. (Dec. 2006).

[57].    Minn. Stat 518.1705 Subd 8 (2007)

[58].    Robert
Emery reports in his research about randomly assigning people to mediation or
litigation inRobert E. Emery, The Truth
About Children and Divorce 136-37 (2004).  After randomly assigning
seventy-one families either to mediation or to court custody battles, twelve
years after going through court or mediation, 28% of the mediation
non-residential parents saw their children once a week as opposed to 9% for the
litigation group.  Id. at 136.  “In the litigation group, 36[%] of
nonresidential parents had not seen their children in the last year
compared with 16[%] of the non-residential parents who mediated.”  Id. at 137.  “Differences in telephone contact were even greater, [which is
important since there were some moves]. . . .  Among families who mediated,
fully 59[%] of non-residential parents talked to their children weekly or more
often compared with just 14[%] of non-residential parents who litigated.”  Id.

[59].    Id. at 136-37.

[60].    Rogerson, supra note 54, at 28 (quoting Rosati v. Dellapenta, 3550 11868/96,
[1997] O.J. 5047 QUICKLAW (Ont. Ct. J. Gen. Div. Nov. 12, 1997)).

[61].    See Minn.
Stat. § 518A.36
subdiv. 2 (2004 & Supp. 2006).

[62].    See id.

[63].    367
N.W.2d 633, 635-36 (Minn. Ct. App. 1985).

[64].    385
N.W.2d at 862-63.

[65].    See id.; Hortis, 367 N.W.2d at 635-36.

[66].    Rogerson, supra note 54, at 26.

[67].    Id. at 20.

[68].    Rosati
v. Dellapenta, 3550 11868/96, [1997] O.J. 5047 QUICKLAW (Ont. Ct. J. Gen. Div.
Nov. 12, 1997)).

[69].    See Faerber, supra note 19,
at 160-224.

[70].    Kathleen
A. Hogan, The Big Case: Issues in High Income/High Asset Cases; Child
Support in High Income Cases
, 17J.
Am. Acad. Matrim. Law.. 349, 351, 355 (2001); Gregory M. Bartlett, Setting
Child Support for the Low Income and High Income Families in Kentucky
, 25N. Ky. L. Rev. 281 (1998).

[71].    Hogan, supra note 70, at 355 (emphasis added).

[72].    McNabb
& Anderson, supra note 31, at 12-14.

[73].    See Bartlett, supra note 70, at
301-303 (describing the complicated and multiple considerations made in
creating child support statutes in the state of Kentucky).

[74].    See 45 C.F.R. §
302.56 (2000).

[75].    See Faerber, supra note 19,
at 160-224.

[76].    Ellman, supra note 38, at 179 n.20 (citing the policy of New York state and Ohio as posted on their child support web pages).

[77].    See Faerber, supra note 19, at 160-224.

[78].    See Ellman, supra note 38, at 167.

[79].    See Faerber, supra note 19, at
160-224.

[80].    Minnesota adopted child support Guidelines in 1983.  1983 Minn. Laws 1757, 1757-59.  The
original Minnesota statute did not require sharing of day care costs which was
added in 1993.  1993 Minn. Laws 2267, 2270.  In 1998 the informal sharing of uncovered
medical expenses was made mandatory by statutory enactment. See e.g.,Improving Child Support Guidelines in Minnesota,supra note 37, at 817 nn.93-94
(explaining Minnesota statutory requirements for medical insurance constituting
“medical support”).

[81].    See Minn. Stat. Ann. § 518.1705 (2004) (defining parenting plans).

[82].    Morton
Deutsch, The Resolution of Conflict: Constructive and Destructive Processes 370 (1973).

[83].    Stockwell
v. Stockwell, 775 P.2d 611, 615-16 (1989) (Johnson, J., concurring specially).

[84].    Id.  “The legal adversarial system asks, ‘Who
will be awarded custody of the minor children?’ The result is that the parent
who is not awarded custody is then labeled a non-custodial, visiting parent. In
many ways, this question is much like the law school professor’s example of an
inappropriate leading question, the most famous of which is, ‘When did you stop
beating your wife?’ Just as the wife-beating question assumes an answer by the
way it is asked, the usual custody question assumes that it is necessary to determine
two levels of ‘ownership’ of the minor children. This is absurd, because the
question of ownership need not even be asked; the focus should be establishing
the parenting obligations that must be practiced in the future by the
spouses.”    Id. at 615 (citing The Legal Dimension, supra note
2, at 108-09.

[85].    See Oregon Statewide Family Law Advisory
Committee (SFLAC), Oregon’s Integrated Family Court of the Future, 40Fam. Ct. Rev. 474, 480 (2002) [hereinafter
Oregon Statewide Family Law Advisory Committee].

[86].    Id.

[87].    See infra Part I.B.1.b.

[88].    See Family Support Act of 1988, Pub. L. No.
100-485, § 101, 102 Stat. 2343, 2344-45 (1988).

[89].    See id.

[90].    SeeHortis, 367 N.W.2d at 635-36.  See
alsoValento
, 385 N.W. 2d at 862-63.  This is also the concept of
requiring one parent to pay directly for health insurance by continuing the
cost through employment as a deduction from one’s salary check.

[91].    SeeValento, 385 N.W. 2d at 862-63; see
alsoBroas v. Broas
, 472 N.W. 2d 671, 673-74 (Minn. Ct. App. 1991)
(the Valento formula was used in a marital dissolution in order to
equalize the parent’s incomes).

[92].    385
N.W. 2d 860.

[93].    SeeMinn.
Stat. § 518A.36 subdiv. 2 (2004 & Supp. 2006).

[94].    See Interview with John Schulz, Partner,
McGrann, Shea, Anderson, Carnival, Straugh, & Lamb, in Minneapolis, Minn.
(Dec. 2006) (explaining his experiences with Post Decree problems experienced
by many high conflict divorcing couples).

[95].    See Neuville, supra note 12,at
5. See also Faerber, supra note 19, at177
n.181 (Georgia allows for a deviation from the guidelines based upon “in-kind
contribution of either parent”).

[96].    See Rogerson, supra note 54, at 20.

[97].    See Morgan, supra note 16.

[98].    Minnesota’s pre- January 1, 2007
“Percentage of Income of Obligor” model is discussed in Section II.A

[99].    Minnesota’s “Income Shares” model effective January 1, 2007 is discussed in Section II.A

[100].    An
exhaustive search of the literature indicates no discussion of the checkbook
method, although the author reports on this as early as 1988.  SeeStephen Erickson,Family Mediation Casebook: Theory and Process (1988). In the Texas case of Bailey v. Bailey, 987 S.W.2d 206 (Tex. App.
1999), Justice Quinn affirmed a trial court judge ruling that the lower court
did not abuse its discretion in: “1) segregating a portion of the support into
an account and specifying how the monies were to be expended; 2) requiring both
parents to jointly determine how the sum would be spent; 3) retaining authority
to disburse the sum if the parents could not jointly agree as to its
disbursement; and 4) awarding to the child the funds remaining in the account
once the obligation to support ends.”  Id. at 207.

[101].    See Faerber, supra note 19,
at 162-265 (summarizing how child support guidelines in each state deal with
various expenses).

[102].    Clothing
costs are seen as a deviation in Arkansas. See Faerber, supra note 19, at 166 n.114.

[103].    See id. at 184 n.222.

[104].    Alabama,
Alaska, Arizona, Arkansas, California, Colorado, Delaware, District of
Columbia, Florida, Hawaii,  Illinois, Indiana, Kansas, Kentucky, Louisiana,
Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana,
Nebraska, New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota,
Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South
Dakota, Texas, Utah, Vermont, Virginia, Washington, West Virginia and Wyoming
all have medical insurance premiums for the children addressed in their
formulas as a separate consideration. See Venohr & Williams, supra note 17, at 19.

[105].    See id. at 20.

[106].    See McNabb & Anderson, supra note
31, at 12. Minn Stat 518A.41 Subd 5

[107].    Educational
needs or extraordinary educational expenses are seen as specifically stated
deviations in Alaska, Arkansas, California, Connecticut, Georgia, Hawaii, Idaho, Illinois, Kentucky, Louisiana, Maine, Minnesota, Nevada, New Hampshire, New Jersey, New York, North Carolina, North Dakota, Ohio, South Carolina, Tennessee, Texas, Virginia, West Virginia, Wisconsin, and Wyoming. Faerber, supra note 19,
at 162-265 (summarizing how child support guidelines in each state deal with
various expenses).  Extraordinary educational expenses are added to the basic
obligation in Vermont.  Id. at 246

[108].    Id. at 177.

[109].    Id. at 184.

[110].    Id. at 212.

[111].    Id. at 169.

[112].    Id. at 219.

[113].    Id. at 166.

[114].    See Neuville, supra note 12, at 5-6.

[115].    Fin
Plan software is available through West Publishing as well as the Family Law
Software available through Dan Caine.

[116].    Carrie
Menkel-Meadow, Whose Dispute Is it Anyway?: A Philosophical and Democratic
Defense of Settlement (In Some Cases)
, 83Geo.
L.J. 2663, 2676-77 (1995).

[117].    Interview
with O.J. Coogler, President, Family Mediation Association, in Atlanta, Ga. (August 1980).

[118].    Id.

[119].    Oregon
Statewide Family Law Advisory Committee, supra note 85, at 480.

[120].    19W. Walton Garrett, Tennessee Practice, Tennessee Divorce, Alimony & Child Custody § 25:1 (2006).

[121].   In  many
instances appellate  courts have disapproved child support awards

that
exceeded what could be deemed to be the child’s reasonable needs. Those courts
which have articulated the rationale for their decisions generally have cited
at least one of three reasons: 1) such support constitutes the distribution of
the obligor parent’s estate; 2) such support provides an inappropriate windfall
to the child; 3) such support may also infringe upon a parent’s right to direct
the lifestyle of his or her children.

Hogan, supra note 70, at 353.  The “three ponies rule” is the humorous rule that says “no
child needs three ponies” as a result of the guidelines formulas being applied
to the extremely wealthy parent.  Id. at 352

[122].    Interview
with Marilyn McKnight, President-Elect of Association for Conflict Resolution
and Family Mediator, Erickson Mediation Institute, in Minneapolis, Minn. (Dec. 2006).

[123].    987
S.W.2d 206 (Tex. App. 1999).

[124].    See supra Part IV.

[125].    Minnesota adopted child support Guidelines in 1983.  1983 Minn. Laws 1757, 1757-59.  The
original Minnesota statute did not require sharing of day care costs which was
added in 1993.  1993 Minn. Laws 2267, 2270.  In 1998 the informal sharing of uncovered
medical expenses was made mandatory by statutory enactment. See e.g.,Improving Child Support Guidelines in Minnesota,supra note 37, at 817 nn.93-94
(explaining Minnesota statutory requirements for medical insurance constituting
“medical support”).

                        author

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