Mandy L. Valentine v. Dan Merrill Valentine

Pocatello, Idaho family law lawyers represented Petitioner and Respondent seeking a divorce.



This case concerns the determination of a student parent's income for purposes of

computing child support and the determination of parents' respective pro rata shares of childcare

expenses. Mandy Valentine ("Mandy”) and Dan Valentine ("Dan”) divorced in 2015. In 2017,

Mandy petitioned the magistrate court for an order modifying the child custody and support

provisions of the divorce decree. The magistrate court did not modify the custody provisions in

the decree but concluded that substantial and material changes in circumstances existed to justify

modifying the child support order. Mandy appealed several aspects of this ruling to the district

court. The district court, sitting in an appellate capacity, affirmed in part and reversed in part the

magistrate court's order. On appeal to this Court, Mandy challenges the district court's conclusion

that her student loans and several other sources of income could be combined to calculate her

income under the Idaho Child Support Guidelines. Dan cross-appeals, challenging the district

court's conclusion that the magistrate court abused its discretion in calculating his pro rata share

of childcare expenses.

Affirmed in part and reversed in part on appeal.