A – State of Delaware

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Part 1: Description of the Child Support Model

A. Overview

In 1984, due to the varied procedures and extensive judicial discretion yielding inconsistent child support award decisions, the US Congress enacted the Child Support Enforcement Amendments. These amendments required states to adopt state-wide advisory child support guidelines by October 1, 1987, based upon “specific and numeric criteria”. However, judges were allowed discretion as to whether to follow the guidelines.1 Although states established guidelines in accordance with the legislation, inconsistencies continued.2

As a result, Congress promulgated the Family Support Act of 1988.3 The Act not only affirmed the use of mathematical child support guidelines but also mandated the use of guidelines as a rebuttable presumption in the determination of child support awards. Further, the Act stipulated that each State must review their guidelines every four years to ensure that their application results in the determination of appropriate child support amounts.4

Delaware enacted its model and formula in 1986 in its “Family Court Rules of Civil Procedure”.5The Delaware Child Support Model6 is based on the following three principles:

• Each parent is entitled to keep a minimum amount of income for his or her basic needs.
• The Melson Formula is considered a rebuttable presumption for calculating child support obligations within Delaware. If the Court finds that the application of the Formula is inequitable in a given case, it must state on the record the result of a calculation pursuant to the Formula and why the application of the Formula would be unjust or inappropriate.7
• The Melson Formula is unique in that incorporates both the income shares and the percentage of income models in the child support formula calculations.

The calculations contained in the first part of the formula are based on the income shares model.8 In these calculations, the amount that is determined to be the basic needs for the child, is shared in proportion to both parent’s income. The calculations in the second part of the formula are based on a percentage of income model.9 In these calculations any income remaining for either parent after an amount is deducted for their basic needs, is shared with the child. This is referred to as their “excess” income. This amount is apportioned by multiplying the same percentage (fixed and based on the number of children) of the excess income of each of the parents.

Furthermore, the Melson Formula contains a number of other elements in the calculations to determine the final child support amount. These include: the number of nights the child spends with each parent, extra expenses incurred for the child such as childcare, tuition costs and health insurance, and a self - protection amount for the paying parent.10 These elements appear at different parts of the formula, and each is explained in more detail and their place in the calculations below in Part C.

To assist parents and family justice officials in determining child support, the Delaware Division of Child Support Services (DCSS), provides various services.11 In addition to establishing child support amounts, the DCSS provides a variety of other services for parents, employers, and child support agencies in other states. These services include establishing paternity, locating a delinquent paying parent, and providing information to parents on how child support is established in Delaware.

As well, they develop and maintain tools to assist parents and family justice officials in determining child support amounts. This includes an online calculator called the Delaware Child Support Formula Calculation12 that incorporates all the factors necessary to generate a final child support amount. Various forms and written instructions for completing child support calculations13 are also made available.

The Melson Formula and the accompanying legislation are reviewed and updated every four years.14 The various percentages and numerical values contained in the formula itself, such as the Self-support Allowance for the parent and the standard of living adjustment amounts, are updated every two years.15 The Family Court Judiciary convenes a committee (the committee) two years after the last review, to begin work on the next review. The committee is presided over by the Chief Judge of the Family Division. Each review period has resulted in changes to the Delaware Formula.

B. How can Parents Obtain a Child Support Award?

In Delaware, either parent can file for a support petition requesting the Court to order the other parent to pay child support. Upon filing the petition, they are required to attend a mediation conference where a Family Court Mediator will be assigned to their case. Using the Melson Formula, the Family Court Mediator will calculate the child support amount and assist the parents in reaching an agreement as to the amount to be paid. The parents may agree to the amount obtained using the Formula, or they may agree to deviate from that amount. If the parents cannot agree, a court hearing will be set to determine the child support amount. In these hearings, the Melson Formula will be used.

As well, either parent also has the option of using the services provided by DCSS. Should they choose this option, DCSS files all actions and pursues any administrative remedies, such as the enforcement of any orders.

C. How the Formula Works16

Part 2 of this summary report includes the specific elements and relevant detailed calculations contained in the formula. However, to assist the reader in understanding the overall approach to the formula calculations, the following is a summary of the four steps that are contained in the Melson Formula. They are as follows:

Step 1 - Calculate each parent’s percentage Share of Total Net17 Income Available for Primary Support

The calculations start with determining the gross annual incomes of both parents and then using various deductions to convert it to a monthly net income.

First, a Self-support Allowance18 is subtracted from both parents’ monthly gross incomes.

Then, if applicable, an adjustment for other dependent children is made. Either parent's available income (minus the Self-support Allowance) can be reduced by 30% in recognition of their duty to support other dependent children. Stepchildren are excluded in this calculation.

This results in an amount for each parent that is entitled the Net Income Available for Primary Support. These amountsare added together to produce the Total Net Income Available for Primary Support.

Finally, each parent’s Net Income available for Primary Support is divided by the Total Net Income Available for Primary Support to produce their respective percentage Share of Net Income Available (for Primary Support).

Step 2 - Calculate the Child(ren)’s Primary Support Need

In this step, the Child(ren)’s Primary Support Need (which is an amount that represents the expenditures needed to cover the basic needs of a child) is calculated by using pre-determined Primary Support Allowance amounts. These amounts are built into the Formula online tool and vary by the number of children.

Added to this amount are three other applicable expenses. These are: childcare expenses necessary for the parent to work, expenses for private school tuition, and health insurance. This produces what is referred to as the Total Primary Need for the children of the action.

The Total Primary Need is then multiplied by each parent’s percentage Share of Total Net Income available for Primary Support. Thiscalculationresults in an amount that represents each parent’s respective Primary Support Obligation.

Step 3 - Calculate the Standard of Living Adjustment (SOLA)

Provided that there is “excess” income after subtracting the Primary Support Obligation from each parent’s Net Income Available for Primary Support, a SOLA is calculated. This “excess” amount is called the monthly Net Income available for SOLA. This allows the child to share in any excess income that the parents may have after meeting their own and their child’s basic needs.

If the Net Income Available for SOLA exceeds $15,000,19 then 20% of the amount that exceeds $15,000 is calculated and is identified as the High Income Offset.20 This amount is subtracted from the Net Income Available for SOLA.

The SOLA percentage, which is the same for both parents, is then identified based on the number of children.21 The Net Income Available for SOLA is multiplied by the SOLA percentage. This generates each parent’s SOLA amount. These are added together to obtain the Total SOLA, which is then divided by the number of children to produce a Per Child SOLA.

Finally, each parent’s Primary Support Obligation amount (calculated in Step 2) is added to their SOLA amount to arrive at the Gross Obligation for each parent.

Step 4 - Calculate Credits, Self-Support Protection Amounts and the final Monthly Net Obligation

In this step, if applicable, three types of credits are calculated that can reduce the finalMonthly Net Obligation (which is the final child support amount to be paid). As well, a final calculation is completedto ensure that the Gross Monthly Obligation for each parent does not cause undue hardship as a result of them having pre-existing child support obligations for children living in other households. This calculation is referred to as a Self-Support Protection Amount.

The first credit calculated for both parents is their Primary and SOLA Retained amount. This amount is calculated by first multiplying the Per Child SOLA amount by the number of children (of the action) living in their respective household, and then adding their respective Primary Support Allowance amount.22

The second credit available to both parents is the calculation of a Parenting Time Adjustment amount. This amount reduces the Gross Obligation for each parentand is designed to acknowledge the costs associated with a greater amount of parenting time. To calculate the second credit, each parent’s Parenting Time Percentage23 is multiplied by the other parent’s Primary and SOLA Retained amount.24

The third credit is called Itemized Primary and recognizes any direct payments by either parent for expenses itemized in Step 2 above, i.e. childcare, primary school tuition and health insurance25. For each parent, these expenses are totalled.

These three credits - the Primary and SOLA Retained, the Itemized Primary and the Parenting Time Adjustment - are then subtracted from the Gross Obligation to produce the Monthly Net Obligation.

A final assessment is then made to ensure that the paying parent is paying an amount within their means. This calculation results in a Self-Support Protection amount.

This amount is a percentage of the Net Income Available for Primary Support. The percentage used is based on whether the parent is supporting children in other households. If the parent is supporting children in three or more households (i.e. has three separate child support orders), the percentage is set at 30% of Net Income Available for Primary Support. If they are supporting children in less than three households then the percentage is 45%. The percentage is multiplied by their Net Income Available for Primary Support to obtain their Self Support Protection amount. This is the maximum support obligation that can be ordered.

The Final Monthly Net Obligation is the lesser of the two amounts - the Self-support Protection amount or the Monthly Net Obligation.

Part 2: Elements of the Child Support Model

A. Data Source Used to Determine Expenditures on the Children

How are expenditures for the child determined?

Three amounts are used in the Formula that are predetermined and are set using the Federal Poverty Guidelines published in the Federal Register by the United States Department of Health and Human Services.26

How are the expenditures reflected in the Formula calculations?

These data sources are used to set the amounts for each of the following components:

• The first is the Self-Support Allowance for each parent. For 2019, the Self-Support Allowance for each parent is $1140 per month. This amount is set at 110% of the Federal Poverty Guideline for a one-person household.
• The second is the Primary Support Allowance for each child. This is an amount that is deemed to meet the children’s basic needs, which are the minimum levels as outlined in the data set used for the development of the federal poverty guidelines. The Primary Support Allowance is comprised of two components:
  • The first is a “per household” component. This amount is set at 25% of the Self-Support Allowance for the parent - minus $72 per month. Rounded to the nearest multiple of 10, this amount is currently set at $210 per month. This is an amount that is set regardless of the number of children that are the subject of the award.
  • The second is a “per child” component. This amount is currently set at 25% of the Self-Support Allowance for the parent plus $24 –or $310 per month. To calculate the Primary Support Allowance, the “per child” component ($310 per month) is multiplied by the number of children, and then added to the “per household” amount ($210 per month).
• The third is the SOLA. After satisfying the parent’s and children’s primary needs, the SOLA allows each child to share in each parent’s economic wellbeing – just as they would have, had the family remained intact. The amount of the SOLA is determined by multiplying predetermined percentages (based on the number of children) by the “excess” income of each of the parents.

B. Approach Used to Apportion the Amount that the Two Parents will Share

The Melson Formula uses a two-part apportioning method for determining the final child support amount:

• The first part, which is common to all income shares models, adds their Net Incomes Available for Support together and divides each by the total to produce their respective percentage share of the Total Net Income Available for Primary Support. These percentages are applied to the Primary Support Amount to determine each parent’s share. These shares are called the parents’ Primary Support Obligation.
• The second part, however, employs a percentage of income model to calculate the SOLA that represents an amount, if applicable, that allows the child to share in any excess income of the parents provided that the basic needs of the parents and child have been met. Predetermined percentages are used (based on the number of children) and applied to the excess income of each parent to generate a SOLA amount.

These two amounts are added together to generate the final child support amount.

C. Accompanying Policy/Legislation (Rules)

i) Determination of income27

The philosophy underpinning the model is based on the “ability to pay” of both parents.

Both parents must provide their gross income.28 Gross income includes all types of income: wages (salaries, commissions, bonuses, and other income), income earned as an independent contractor, and all other taxable income that does not come from earnings (e.g. dividends, severance pay, pensions, workers' compensation, alimony received, etc.).

The Formula includes a Self-Support Allowance for each parent. As noted above, for 2019 the Self-support Allowance for each parent is $1140 per month.

There are a limited number of Allowable Deductions from gross income, that when applicable, are subtracted from gross income.  These deductions include: medical and disability insurance premiums, pension deductions, union dues, and court ordered spousal support.

Lastly, if applicable, there is a deduction for Other Dependents from a parent’s available income to recognize the parent’s duty to support all their children. Stepchildren are excluded and children outside the household are only counted if there is a court order for support or there is a pattern of support established. This is a called an Adjustment for Other Dependents and the claiming parent’s income (following subtraction of allowable deductions and the Self- Support Allowance) is reduced by 30%.

With the exception of disability income that a child may receive, the guidelines only require the parent's income. No other income from a child is included in the calculations. Disability income for a child normally comes from the Social Security System and if the payment is made due to the child's disability, then the income is attributed to the household in which the child primarily resides. If the payment is a dependent benefit made on account of the obligated parent's disability, then it is attributed as income to the disabled parent. However, in these situations, the parent gets a dollar for dollar credit for the dependent benefit disbursed to the child's household.

ii) Income attribution

If a parent is unemployed, underemployed, or fails to provide adequate documentation of their wages, the court may attribute income to them. In order to determine how much income will be attributed to the parent, the court examines earnings history, employment qualifications, and the current job market.

Built into the model is the assumption that every parent has a “capacity to earn” at least an amount that is equivalent to half of the state-wide median wage for a 40-hour week.29

iii) Impact of custody and parenting time

The Melson Formula incorporates the amount of time parents spend with their children into the construction of the formula. The type of parenting time or custody arrangement (shared parenting or high access) affects where in the application of the formula, adjustments are made.

Shared parenting

To be considered to have shared equal placement, each parent must have the child over 163 nights per year (45% of the year). In these cases, a child is counted as one-half (.5) and this is applied to the per child component of the Primary Support Allowance (i.e. .5 times $310=$165). This calculation is completed early on in the formula application30 and affects all other steps in the formula as it identifies the number of children in the household.

Parenting time

Where the child has primary residence with one of the parents and the other parent has the child between 80 to 124 overnights per a year, there is a 10% adjustment. If the number of overnights per year is between 125 and 163, a 30% adjustment is made. This adjustment is made after calculating the Primary Support Obligation and the SOLA and is subtracted from the Gross Obligation. It forms part of the final calculations that are completed to determine the Monthly Net Obligation. This calculation allows the parent to retain a percentage of the Primary Support Allowance and the parents combined SOLA, and results in credits that reduce the Final Net Obligation. It is designed to recognize the time the parent spends with the child. If the paying parent has the child less than 79 nights per year, no credit is provided.

Split custody

In cases of split custody, and where they each have the children for over 163 overnights, both parents complete the calculations using the formula based on the number of children they have in their care. The parent with the higher Monthly Net Obligation will pay the difference to the other parent.

iv) Special expenses

Childcare costs, medical expenses (not including insurance premiums) and private tuition are called Primary Expenses and are included in the formula as part of the calculation of the child’s Primary Support Need. All of these expenses must be verified and agreed upon by the parents.31

v) Concept of undue hardship

Included in the Melson Formula is a final step in the calculation that is designed to ensure that the final child support amount for the paying parent does not cause undue hardship as a result of existing support obligations for other children in other households. This calculation is referred to as a Self-Support Protection Amount. This calculation sets a maximum support obligation that the Monthly Net Obligation calculated by the formula cannot exceed. The threshold is calculated as a percentage of the parent’s Net Income Available for Primary Support.

vi) Other circumstances that could be considered that may result in a variation to the formula amount

• Disabled parents who qualify for a government disability benefit are assessed on a case-by-case basis. There are no special provisions for disabled children.
• Variations to a child support amount are allowable before 2.5 years after the order is made, provided that there is a substantial change in circumstances not caused by the petitioner’s voluntary or wrongful conduct and the variation results in more than 10%. There are no such requirements for variations after 2.5 years.
• Administrative adjustments by the Division of Child Support Services (DCSS) can be made when a change occurs that is required by law – such as when a parent under a current child support order misses their payments for one calendar month. An arrears payment will automatically be added to the order.
• The coming into force of any changes to the legislation does not in and of itself, constitute grounds for a modification to the child support amounts.

vii) Other considerations

Age of the child: Child support orders automatically terminate when all minor children have reached the age of 18 and have graduated from high school. If the child is over 18 and has not finished high school, the child support will terminate when the child is 19 or when the child receives a high school diploma – whichever occurs first.

Minimum support: if the children reside in a sole custody situation (less than 79 overnights), the Court can impose a minimum order of no less than $100 per month for one child and $170 per month for more than one child.

Maximum support: There is no stated maximum support, however, the SOLA calculation includes a High Income Offset that seeks to reduce the amount of support paid at high-income levels, e.g. those earning over $180,000 per year. The offset amount is 20% of income in excess of $15,000 a month, which is subtracted from a parent’s Net Income Available for SOLA.

Part 3: Summary of Key Changes to the Child Support Guideline Legislation

A. Overview of the Changes

This section summarizes the key amendments to the child support legislation. The first set of amendments occurred in 1990. Two changes are noteworthy:

• Amendments were made to not allow the inclusion of childcare expenses as an add-on to the Children’s Primary Support Need as they were considered to be included in the Primary Support Allowance; and
• The definition of income was modified to exclude the income of a person co-habiting with either parent.

Over the next twelve years (1990 – 2002) various amendments to the child support legislation were made, however, these changes mainly pertained to clarifying the definition of income. The clarifications included what constitutes income for the purposes of child support, how to treat income that parents may have earned from a second form of employment, as well as other minor amendments.

2002

The next major change to the legislation occurred in 2002 when amendments were made to change the calculations of the combined SOLA and the Primary Support Allowance depending on the amount of time the child spent with the paying parent. Prior to 2002, both of those adjustments were shared equally between the parents if the child resided in each parent’s home an equal amount of time. Under the amendments, the formula was changed to give parent’s with whom the child resides more than 30% but less than half the number of overnights, the opportunity to share in in a portion of the combined SOLA.

As well, the legislation was amended to change the calculations in the formula for other dependent children. Instead of deducting an amount for those children after the final child support amount was determined, the calculations were amended to require a deduction of an amount for other dependent children from the gross income calculation. In addition, there were also a series of amendments that further clarified how deductions from income for pension contributions and other minor deductions were to be treated.

2014

In 2014, further amendments were made pertaining to the number of overnights the child spent with each parent and how these would be categorized. In these amendments, the ranges of the number of overnights were changed. The “number of overnight” bands were collapsed from six to four, and the lowest threshold number of overnights that provided the parent spending time with the child with a credit for their time, was changed from 109 (30%) to 79 (22%) overnights.

201532

Significant changes occurred again in 2015. These amendments resulted in further to changes to the way in which the formula calculations took into consideration any existing financial responsibilities that either parent had for other minor children from other relationships. Prior to this revision, the Court reduced the parent's available income for primary support by only taking 83% of the parent’s available income if there was one other child, 73% if there were two other children, and 67% for three or more children. In order to simplify the calculation, the parent’s available income for primary support was reduced by 30% regardless of the number of other children they support.

As well, the number of overnights to trigger a "parenting time adjustment" for the support payer was revised. Prior to January 1, 2015, a parent was entitled to a 10%, 20%, 30%, or 40% adjustment to his/her support obligation based on the number of overnights the child spent with the parent, i.e. four bands of parenting time. The requirement for a parenting time adjustment was simplified to two bands: 80 to 124 overnights per year results in a 10% adjustment and 125 to 163 overnights per year results in a 30% adjustment.

201933

The committee completed their last review in November 2018 and issued their report recommending adjustments to the Melson Formula. These recommendations have been accepted and came into effect on February 1, 2019.34 These recommendations complement the changes to the federal regulations that are a result of the United States Supreme Court ruling in Turner v. Rogers whereby the Court upheld that the ability to pay is a critical element in any child support enforcement proceeding.

The changes included:

• Eliminating deductions for taxes on income (federal, state and city) and social security and thus using the parents’ gross incomes as opposed to net incomes for the calculations.
• Raising the Self-Support Allowance amount and lowering the (SOLA) percentages by number of children35 in order to account for the change from net to gross income.
• Revising the SOLA calculation. Currently, if either parent’s net available income for the SOLA exceeds $15,000 per month (approximately $200,000 total earnings per year), each parent’s net income available for the SOLA is to be reduced by 20% of the combined excess.

As well, several changes were implemented that were designed to recognize the difficulties that lower income parents face in providing for themselves and their children. These included:

• Increasing the numerical amounts for primary allowances for children and the parents’ Self-support Allowance.
• Adjusting the child support obligation of paying parents who are incarcerated.
• Providing clarification on how to impute income.
• Lowering the self-support protection mechanism in cases when a parent has children in 3 or more households to support.

B. Overview of Leading Case Law on the Child Support Model

• Ford v. Ford, 609 A. 2d 25 (Del. Supr. 1991)36 – The Delaware Supreme Court cautioned that the Melson Formula calculation should not become a method for the transfer of wealth from one parent to the other parent.
• Dalton v. Clanton, Del. Supr. 559 A.2d 1197 (1989)37 – Criteria on when the application of the Formula would be unjust or inappropriate.
• Turner v. Rogers, 564 U.S. 431 (2011)38 – Ability to pay as a critical element in enforcement proceedings.

Part 4: Summary of the Literature that Assesses the Model

A review of the available literature on the advantages and disadvantages of the various elements of the Delaware model revealed the following.39

A. Advantages

• The underlying philosophy is fair and equitable in that it sequences a parent’s obligations. The Formula holds parents responsible for meeting their own essential needs first, the essential needs of their children second, and the “affluence-related” needs of their children last.40 
• The approach has the effect of simultaneously maintaining accuracy and enhancing equity in the determination of support.41
• Through the use of a Self-support Allowance, the model is more equitable for parents with limited ability to pay.42
• Produces less extreme differences in living standards where one parent has a very low income and the other parent has significantly higher income.43
• It is the only model that strives to address the prevention of poverty. The model does this by setting basic child support and parental self-support reserves at a percentage of the federal poverty guidelines.44

B. Disadvantages

• Poverty figures used in the Formula are what the federal government uses as a measure of the relative wellbeing of the nation’s citizens and is the basis for the level of federal funding paid to states to provide for food supplements and various welfare-related programs. It represents a minimum standard of living recognized as the level below which citizens shouldn’t live. It is assumed that the standard of living established by the poverty guidelines does indeed provide a minimum subsistence standard for food, housing and other needs. Critics of the Melson Formula argue that the use of those levels understates a person’s subsistence needs, while others claim they exaggerate those needs.45 
• The poverty levels used also make no distinction between adults and children. The initial level for a one-person household is supplemented by a standard amount for each person added, either child or adult, and regardless of the size of the household. A three-person household consisting of two adults and one child has the same value as a one adult, two children household, making the values not reliable. It is important to note, that the Delaware Review Panel recently recognized this problem and have revised the calculations used for the self-support reserves.46

Part 5: Selected Case Scenarios Using the Melson Formula

Delaware provides a calculator tool on its website. The following tables present the results from two case scenarios – one simple and one complex. All amounts are in US dollars.

Case Scenario 1: Fred and Jane have two children, Tom and Sally, both under the age of 18. There are no other dependent children. Fred has care and custody of Tom and Sally for 50 overnights per year. The parents have annual gross incomes of $50,000 (Fred) and $30,000 (Jane).

Case Scenario 2: Jonathan and Frieda have one child named Sandy. She is under the age of 18; Jonathan has care and custody of Sandy for 140 overnights per year. Jonathan is also the parent of a dependent child named Gino, who he lives with. He is under the age of 18. Jonathan resides with Gino. Frieda has an annual gross income of $150,000 and pays alimony to a previous spouse of $9600 annually. Jonathan has an annual gross income of $400,000, plus a second job that provides him with $10,000 annually. He also makes $5000/month pension contributions. Jonathan also pays private tuition fees for Sandy of $6,000 annually.

All amounts are in US dollars.

The detailed calculations for the two scenarios are attached as Appendix B.

Appendix A: References

Beld, Jo Michelle. “Improving Child Support Guidelines in Minnesota: The "Shared Responsibility" Model for the Determination of Child Support.” William Mitchell Law Review, Volume 28, Issue 2 Article 9 (2000).
https://open.mitchellhamline.edu/cgi/viewcontent.cgi?article=1663&context=wmlr

Delaware.gov. Frequently asked Questions: Child Support Services.
https://www.dhss.delaware.gov/dcss/faq.html

Erickson, Nancy S. “Child Support Guidelines: A Primer.” 26 Clearinghouse Rev. 734 (1993-1994).
https://heinonline.org/HOL/LandingPage?handle=hein.journals/clear27&div=102&id=&page=&t=1559232768

Hunter, Nan D. Child Support Law and Policy: The Systemic Imposition of Costs on Women. Georgetown University Law Center, 1983.
https://scholarship.law.georgetown.edu/cgi/viewcontent.cgi?referer=https://www.google.com/&httpsredir=1&article=2734&context=facpub

Meyer, Charles J., Soulen, Justin W., and Goldberg Weiner, Ellen. “Child Support Determinations in High Income Families - A Survey of the Fifty States”. Journal of the American Academy of Matrimonial Lawyers, (March 2016).
http://aaml.org/sites/default/files/MAT209_5.pdf

Pottruff, Betty Ann, Q.C. Child Support Guidelines- The Future of the Fringe of Dealing with Child Poverty. Public Law and Policy Division, Policy, Planning, and Evaluation Branch, Government of Saskatchewan.
http://redengine.lawsociety.sk.ca/inmagicgenie/documentfolder/AC1463.pdf

State of Montana. The Guidelines Review Project: A Primer for the Participants. Guidelines Review Project. 2009.

The Castro Firm, Inc. “How is child support calculated in Delaware?”
http://thecastrofirm.com/how-is-child-support-calculated-in-delaware/

The Family Court of the State of Delaware. Form 509I, Rev 3/19. “Instructions for Child Support Calculation (2019)”.
https://courts.delaware.gov/Forms/Download.aspx?id=109568

The Fathers Rights Network. “Child Support - Melson Formula Method.”
http://fathersrightsnetwork.net/home/wiki/custody-and-divorce-terms/child-support---melson-formula-method

The Honourable Michael K. Newell, Chief Judge. Report of the Family Court Judiciary, the Family Court of the State of Delaware, Delaware Child Support Formula Evaluation and Update, November 8, 2018. https://courts.delaware.gov/forms/download.aspx?id=39228

The Yeager Law Firm LLC. “Top 5 Changes to Delaware Child Support Formula, Effective January 1, 2015.” (September 8, 2015)
http://www.yeagerfamilylaw.com/blog/2015/9/13/top-5-changes-to-delaware-child-support-formula-effective-january-1-2015

United States. National Archives. Federal Register. Annual Update of the HHS Poverty Guidelines.
https://www.federalregister.gov/documents/2018/01/18/2018-00814/annual-update-of-the-hhs-poverty-guidelines

Contact Person
Andrew Southmayd
Commissioner
Family Court of the State of Delaware.

Appendix B: Two Case Scenarios

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