Ward v. McGarry
Ward v. McGarry, 2024 UT App 169 (Christiansen Forster, J.)
Family Law
Following a trial on remand, the district court entered a new child support award. Mother appealed the award and challenged the decision not to sanction Father. The Utah Court of Appeals affirmed, holding:
- The district court did not abuse its discretion in determining Father’s income.
- The district court did not abuse its discretion by not sanctioning Father.
- Practice tip: In contested cases involving child support, a parent’s income may be imputed only if a hearing is held and the judge enters findings of fact as to the evidentiary basis for the imputation.