This opinion is nonprecedential except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c).
STATE OF MINNESOTA IN COURT OF APPEALS A24-1066
County of Dakota, ex rel., petitioner, Respondent,
Michelle Marie Hinz, petitioner, Respondent,
vs.
Bryan Arthur Rittweger, Appellant.
Filed September 2, 2025 Affirmed Cochran, Judge
Dakota County District Court File No. 19WS-FA-19-909
Kathryn M. Keena, Dakota County Attorney, Brita A. Carnine, Assistant County Attorney, West St. Paul, Minnesota (for respondent County of Dakota)
Johanna P. Clyborne, Brekke, Clyborne & Ribich, L.L.C., Shakopee, Minnesota; and
Kala Swenson, Collins, Buckley, Sauntry & Haugh, P.L.L.P., St. Paul, Minnesota (for respondent Michelle Marie Hinz)
Francis Herbert White III, Francis White Law, PLLC, Woodbury, Minnesota (for appellant)
Considered and decided by Schmidt, Presiding Judge; Reyes, Judge; and Cochran,
Judge. NONPRECEDENTIAL OPINION
COCHRAN, Judge
Appellant filed a motion to modify his child-support obligation, alleging a
substantial change in his income and requesting a reduction in his child-support arrearages.
The child support magistrate (CSM) granted appellant’s motion to reduce his child-support
obligation but denied his request to reduce his child-support arrearages. The CSM also
ordered appellant to make a monthly payment in a set amount to satisfy the arrearages.
Appellant challenges the CSM’s order, arguing that the CSM abused her discretion
when she did not reduce his arrearages and when calculating his monthly arrearage
payment. Appellant also argues that certain child-support statutes are unconstitutional as
applied. Because we discern no abuse of discretion and the constitutional arguments are
not properly before us, we affirm.
FACTS
Appellant Bryan Arthur Rittweger and respondent Michelle Marie Hinz are the
parents of two children, who were aged 16 and 17 at the time of filing of the order at issue
in this appeal. Rittweger and Hinz were never married, and Hinz had sole physical custody
of the children. Respondent County of Dakota is the public authority charged with child-
support enforcement and became involved due to Hinz’s application for public assistance
and child-support services.
In August 2019, the county filed a motion to establish child support. A CSM granted
the county’s motion and ordered Rittweger to pay $1,434 per month in child support and
$160 in medical support. The CSM also determined that Rittweger owed Hinz $31,540.70
2 for past basic child support and owed the state $1,280 for past medical and dental expenses
expended on behalf of the children.
In August 2023, the county filed a motion to hold Rittweger in contempt of court,
alleging that he had $99,256 in arrearages on his child-support obligation. The district
court subsequently ordered Rittweger to show cause as to why he should not be held in
contempt.
On November 30, 2023, Rittweger filed and served the motion to modify child
support at issue in this appeal. His motion requested a decrease in his basic monthly child-
support obligation due to his inability to work. The motion also requested a reduction in
his arrearages based on Hinz’s receipt of social security disability income (SSDI)
derivative benefits and veterans affairs (VA) apportionment benefits on behalf of the
parties’ joint children. In support of his motion, Rittweger filed an affidavit alleging that
he had been adjudicated eligible for SSDI. He further alleged that Hinz received two lump
sum SSDI derivative benefits on November 4, 2023—one for each child in the amount of
$6,919.75—and thereafter received $485 per month in SSDI derivative benefits for each
child. Rittweger also alleged that, since February 2021, Hinz had been receiving $450 per
month in apportioned VA benefits on behalf of the children. Rittweger asserted that none
of these benefits were credited towards his past-due child-support obligation and that these
benefits amounted to at least “$32,429.50 in child support payments.” Rittweger requested
that his child-support obligation be credited for these benefits.
Hinz filed a responsive motion requesting that the CSM deny Rittweger’s motion to
modify child support and instead order Rittweger “to continue to pay any excess payments
3 and additional funds towards the arrears accrued.” Hinz confirmed in her affidavit that she
received the SSDI and VA apportionment benefits as detailed by Rittweger.
Prior to the motion hearing, the parties agreed that Rittweger’s ongoing monthly
child-support obligation should be reduced to zero dollars, effective November 1, 2023, as
a result of his inability to work and because Hinz was receiving ongoing VA and SSDI
benefits on behalf of the children. But the parties were not able to reach an agreement on
the issue of child-support arrearages and whether the VA and SSDI benefits that Hinz had
received on behalf of the children should be credited towards the arrearages accrued prior
to the modification of Rittweger’s child-support obligation.
Following a motion hearing, the CSM issued a written order denying Rittweger’s
motion to credit his arrearages balance with the amount that Hinz had received in lump
sum SSDI benefits and monthly VA benefits. The CSM found that Rittweger had “not
made any voluntary payments of child support since the 2019 order[,]” and that he owed
over $100,000 in arrearages as of January 16, 2024 but the “amount has decreased due to
payments withheld from his social security disability since November 1, 2023.” The CSM
determined that granting Rittweger’s request to credit his arrearages would amount to an
impermissible retroactive modification of Rittweger’s child-support obligation. In
reaching her decision, the CSM relied primarily on the Minnesota Supreme Court’s
decision in Dakota County v. Gillespie, 866 N.W.2d 905 (Minn. 2015). Based on Dakota
County, the CSM reasoned that child-support payments and dependent VA and SSDI
benefits are “distinct entitlements due to the children from separate sources.” Thus, the
CSM determined that the VA and SSDI benefits were not child-support payments and
4 therefore could not be applied to Rittweger’s arrearages without being considered a
retroactive modification of child support.
The CSM also ordered Rittweger to make monthly payments towards his arrearages.
Based on the child-support guidelines, the CSM determined that Rittweger’s monthly
support obligation would be $1,181. But, in calculating the obligation, the CSM did not
include the usual downward adjustment for court-ordered parenting time. Instead, the
CSM explained that no adjustment was made because Rittweger’s parenting time was “not
actually taking place.” The CSM also noted that Rittweger had not made any payments
towards his child-support obligation, which had caused “financial hardship for the children
in their household.” Consequently, the CSM determined that the monthly payment amount,
without the parenting-expense adjustment, would “result in the payment of the arrears
balance within a reasonable time that [would] benefit the joint children and [would] not
cause financial hardship upon [Rittweger] given his current level of income.” Rittweger
did not seek review of the CSM’s decision by the district court. See Minn. R. Gen. Prac.
376.03 (allowing for a motion for review of a CSM’s order by a district court judge).
Rittweger appeals.
DECISION
Rittweger challenges the CSM’s order on his motion to modify child support,
arguing that the CSM abused her discretion when she denied his request to reduce his child-
support arrearages by an amount equal to the sum of the SSDI derivative benefits and VA
apportionment benefits received by Hinz on behalf of their joint children. He also contends
that the CSM abused her discretion when she did not make an adjustment for Rittweger’s
5 court-ordered parenting time in her calculation of his monthly arrearage payments. We
consider each argument in turn.
I. The CSM did not abuse her discretion when she denied Rittweger’s request to credit his child-support arrearages accrued prior to the modification of his child-support obligation based on the VA apportionment and SSDI derivative.
Rittweger raises two arguments in support of his contention that the CSM abused
her discretion when she denied his request to reduce his child-support arrearages to account
for Hinz’s receipt of VA apportionment and SSDI derivative benefits on behalf of the
children. First, Rittweger argues that the CSM erred as a matter of law in her application
of child-support statutes and in her reliance on Dakota County. In the alternative,
Rittweger argues that the CSM’s reliance on certain child-support statutes violates the
Supremacy Clause and the Fourteenth Amendment Due Process Clause of the United
States Constitution. Neither argument is persuasive.
Motion to Modify Arrearages
“The district court has broad discretion when deciding child-support modification
issues.” Shearer v. Shearer, 891 N.W.2d 72, 77 (Minn. App. 2017) (quotation omitted).
We review an order on a motion to modify child support for an abuse of discretion.
Haefele v. Haefele, 837 N.W.2d 703, 708 (Minn. 2013). 1 “A district court abuses its
discretion by making findings of fact that are unsupported by the evidence, misapplying
1 “On appeal from a CSM’s ruling, the standard of review is the same as it would be if the decision had been made by a district court.” Hesse v. Hesse, 778 N.W.2d 98, 102 (Minn. App. 2009).
6 the law, or delivering a decision that is against logic and the facts on record.”
Woolsey v. Woolsey, 975 N.W.2d 502, 506 (Minn. 2022) (quotation omitted).
Under Minnesota Statutes section 518A.39 (2024), a court may modify a child-
support obligation in certain circumstances including when an obligor has a substantially
decreased gross income. Minn. Stat. § 518A.39, subd. 2(a). But a motion to modify child
support generally may not be made retroactive beyond the date when the party seeking
modification served the notice of motion for modification on the responding party. Minn.
Stat. § 518A.39, subd. 2(f). And “[b]ecause forgiveness of arrearages is a retroactive
modification of support, arrearages accruing prior to service of the modification motion
may not be forgiven.” Allan v. Allan, 509 N.W.2d 593, 597 (Minn. App. 1993). However,
the district court may adopt an alternate effective date for the modification of child support
upon agreement of the parties. Minn. Stat. § 518A.39, subd. 2(f), (l).
Here, Rittweger served his motion to modify child support on Hinz on
November 30, 2023. Pursuant to that motion, the parties agreed to modify Rittweger’s
child-support obligation effective November 1, 2023. Consequently, any modification of
his child support could not be made retroactive prior to November 1, 2023, including
forgiveness of arrearages. Allan, 509 N.W.2d at 597; Minn. Stat. § 518A.39, subd. 2(f).
As explained below, the VA apportionments and SSDI derivative benefits paid to Hinz on
behalf of the joint children did not satisfy any portion of Rittweger’s existing child-support
obligation. See Dakota County, 866 N.W.2d at 913 (stating that SSDI derivative benefits
“are not used to satisfy an obligor’s child support obligation”). Consequently, Rittweger’s
request that the CSM reduce his arrearages by the amount of the SSDI lump sum benefits
7 and VA apportionment benefits that Hinz received on behalf of the parties’ joint children
is a request to modify child support beyond the date agreed to by the parties. See Minn.
Stat. § 518A.39, subd. 2(f) (stating the district court may adopt an alternate effective date
for a modification of child support); Allan, 509 N.W.2d at 597 (stating that “forgiveness of
arrearages is a retroactive modification of support”). Therefore, the CSM did not abuse her
discretion when she denied Rittweger’s request to reduce his child-support arrearages
based on Hinz’s receipt of the SSDI lump sum benefits and VA benefits.
We are not persuaded otherwise by Rittweger’s argument that Minnesota Statutes
sections 518A.31(c) and 518A.34(g) (2024) require the application of these benefits to his
child-support arrearages. Minnesota Statutes section 518A.31 (2024) governs the
treatment of SSDI and VA benefits received on behalf of a child. That statute provides
that, when calculating a parent’s presumptive child-support obligation, SSDI benefits and
apportioned VA benefits “provided for a joint child shall be included in the gross income
of the parent on whose eligibility the benefits are based.” Minn. Stat. § 518A.31(a). The
statute further provides that, if SSDI benefits or apportioned VA benefits are “provided for
a joint child based on the eligibility of the obligor, and are received by the obligee as a
representative payee for the child, . . . then the amount of the benefits shall also be
subtracted from the obligor’s net child support obligation.” Id. (c). And, in calculating a
parent’s presumptive child-support obligation, the district court is required to subtract
SSDI derivative benefits and apportioned VA benefits that are paid to the obligee on behalf
of the joint children. Minn. Stat. § 518A.34(a), (g) (2024). But these provisions do not
8 address modification of an existing child-support obligation or retroactive forgiveness of
child-support arrearages.
The supreme court’s decision in Dakota County is instructive on this issue. In
Dakota County, the supreme court interpreted the language of sections 518A.31(c) and
what is now 518A.34(g) 2 in the context of SSDI derivative benefits. 866 N.W.2d at 909-
11. There, the obligor argued that he should receive credit for an “overpayment” of his
existing child-support obligation due to SSDI derivative benefits that the obligee received
on a monthly basis on behalf of the children. Id. at 908-09. The supreme court concluded
that SSDI derivative benefits “are not used to satisfy an obligor’s child support obligation”
because sections 518A.31(c) and 518A.34(g) are not independent mechanisms to offset an
existing obligation. Id. at 913. Instead, sections 518A.31(c) and 518A.34(g) provide that
an obligor’s SSDI derivative benefits received by the obligee on behalf of the joint children
be considered as a part of the calculation of the obligor’s child-support obligation. Id. at
911-12. The supreme court continued that, in the absence of a statutory exception, an
obligor’s child-support obligation can only be recalculated by modification. Id. at 912.
And the supreme court emphasized that—under the then-applicable version of the support
modification statute—modifications to child-support obligations “may be retroactive only
2 In Dakota County, the supreme court cites section 518A.34(f) (2014) when discussing the treatment of SSDI and VA benefits received by a parent on behalf of a joint child. 866 N.W.2d at 911. Effective August 1, 2018, the language of section 518A.34(f) was moved to section 518A.34(g). 2016 Minn. Laws ch. 189, art. 15, § 18, at 1117-19.
9 to the date of service of notice of the motion to modify.” 3 Id. As a result, the supreme
court concluded that “prior to the obligor moving the district court for a modification, the
obligee was legally entitled to both the derivative Social Security benefits and child support
under the existing order.” Id. at 912-13.
As Dakota County makes clear, Rittweger’s reliance on sections 518A.31(c) and
518A.34(g) to argue his arrearages should be reduced confuses the satisfaction of a parent’s
existing child-support obligation with the calculation of the parent’s child-support
obligation. As discussed above, the supreme court determined in Dakota County that
sections 518A.31(c) and 518A.34(g) do not authorize the subtraction of benefits paid to
the obligee on behalf of the children to “satisfy an obligor’s child support obligation.” Id.
at 913 (emphasis added). Instead, sections 518A.31(c) and 518A.34(g) allow for the
subtraction of benefits paid to the obligee on behalf of the children when calculating a
parent’s basic child-support obligation. Id. at 912. And because Rittweger’s child-support
obligation could be recalculated only pursuant to a motion to modify child support,
Rittweger was not entitled to credit for SSDI and VA benefits paid to Hinz on behalf of the
3 On August 1, 2015, shortly after the supreme court filed its decision in Dakota County, an amendment to section 518A.39, subdivision 2, went into effect, which allowed for parties to agree to an alternate effective date for a child-support order and the modification of child support to that date. 2015 Minn. Laws ch. 30, art. 1, § 11, at 280-82 (codified at Minn. Stat. § 518A.39, subd. 2 (e), (l)); see Minn. Stat. 645.02 (2024) (stating that a law not making appropriations takes effect “August 1 next following its final enactment, unless a different date is specified in the act”). Because Rittweger does not assert that any arrearages occurred between November 1, 2023—the agreed to effective date for the modification of child support—and November 30, 2023—the date of service of the motion to modify child support—the amendment does not affect our analysis.
10 children towards his arrearages existing as of November 1, 2023—the agreed upon date for
modification of his child-support obligation. Id. at 912-13. 4
Rittweger argues that, notwithstanding the supreme court’s holding in Dakota
County, the CSM should have credited his arrearages for the SSDI and VA benefits paid
to Hinz for two reasons. First, Rittweger argues that this case is distinct from Dakota
County because Dakota County addressed an obligor’s request for prospective credit for
SSDI derivative benefits already paid in excess of an obligor’s existing child-support
obligation, whereas here Rittweger is requesting that the VA and SSDI benefits be applied
retroactively to his arrearages existing as of November 1, 2023. But Rittweger does not
explain why this difference should result in his arrearages being credited. Regardless of
whether the benefits are being credited prospectively to future child-support payments or
retroactively to arrearages, the request is still to apply the SSDI and VA benefits “to satisfy
an obligor’s child support obligation.” Id. at 913. As described above, SSDI and VA
benefits are used to calculate a parent’s child-support obligation rather than to satisfy a
child-support obligation. See id. (stating that “upon a motion to modify the child support
order, such benefits result in a recalculation and reduction of the obligor’s obligation”
(emphasis added)). Rittweger also fails to address the bar to retroactive modification of
child support, including arrearages that accrued before effective date of a modification of
child support. See Minn. Stat. § 518A.39, subd. 2(f); Allan, 509 N.W.2d at 597.
4 We note that the legislature has made relevant amendments to sections 518A.31 and 518A.34(g). 2023 Minn. Laws ch. 70, art. 14, §§ 27, at 3959-60, 30, at 3960-62. However, these amendments are not applicable in this case because the CSM’s order was entered on May 3, 2024, before these amendments went into effect on January 1, 2025. Id.
11 Second, Rittweger argues that the VA apportionment should be treated differently
than the SSDI derivative benefits because Dakota County only concerned SSDI derivative
benefits, and a veteran has a constitutionally protected property interest in their VA
benefits. But an SSDI recipient also has a constitutionally protected property interest in
their SSDI benefits. Mathews v. Eldridge, 424 U.S. 319, 332 (1976). Notwithstanding this
protected interest, our supreme court determined that sections 518A.31(c) and 518A.34(g)
do not permit a child-support obligation to be satisfied by SSDI derivative benefits prior to
a motion to modify. Dakota County, 866 N.W.2d at 913. And the United States Supreme
Court has said that Congress intended veterans’ disability benefits “to be used, in part, for
the support of veterans’ dependents.” Rose v. Rose, 481 U.S. 619, 631 (1987). Also,
sections 518A.31(c) and 518A.34(g) address “veterans’ benefits” alongside “Social
Security” in specifying what amounts get deducted when calculating a parent’s basic child-
support obligation. See Minn. Stat. § 518A.31(c) (stating that if “Social Security or
apportioned veterans’ benefits are provided for a joint child,” they are subtracted from an
obligor’s net child-support obligation when the obligee receives the benefits on behalf of
the joint child (emphasis added)). Thus, while Dakota County concerned only SSDI
derivative benefits, the CSM did not abuse her discretion when she concluded that the
holding in Dakota County also applied to VA apportionment benefits.
Therefore, while Rittweger is to be commended for his military service, the CSM
did not misapply the law when she denied Rittweger’s motion to credit his arrearages that
were accrued prior to the effective date of the modification of Rittweger’s child-support
obligation to account for the VA benefits and SSDI lump sum payments received by Hinz
12 on behalf of the children. See Minn. Stat. § 518A.39, subd. 2(f), (l) (stating that the parties
may agree to an effective date for a modification of child support); Allan, 509 N.W.2d at
597 (stating that “forgiveness of arrearages is a retroactive modification of support”).
Constitutional Challenge
Rittweger also argues that sections 518A.31(c) and 518A.34(g) are unconstitutional
as applied in this case. Rittweger argues that these statutes violate the Supremacy Clause
and Fourteenth Amendment Due Process Clause of the United States Constitution.
Respondents argue that this argument is not properly raised on appeal because Rittweger
did not raise this issue with the CSM. We agree.
“[C]onstitutional issues that were not raised in the [district] court” cannot be raised
for the first time on appeal. In re Welfare of C.L.L., 310 N.W.2d 555, 557 (Minn. 1981);
see also Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988) (stating that appellate courts
“must generally consider only those issues that the record shows were presented and
considered by the [district] court in deciding the matter before it” (quotation omitted)). The
record reflects that Rittweger failed to raise the issue of the constitutionality of sections
518A.31(c) and 518A.34(g) below. Before the CSM, Rittweger’s counsel stated only that
he was “considering the possibility that it may become necessary to challenge the
constitutionality of [sections 518A.31(c) and 518A.34(g).]” (Emphasis added.) But there
is no indication in the record that Rittweger ever actually challenged the constitutionality
of the statutes before the CSM. And, at oral argument, Rittweger conceded that the above
statement is the only statement that he made to the CSM regarding the constitutionality of
the statutes. Because Rittweger did not present this argument to the CSM, Rittweger’s
13 constitutional challenge to the CSM’s decision is not properly before us and we decline to
consider the issue. See C.L.L., 310 N.W.2d at 557; Thiele, 425 N.W.2d at 582.
II. The CSM did not abuse her discretion in calculating Rittweger’s monthly arrearage payment.
Rittweger further argues that the CSM abused her discretion by ordering Rittweger
to pay a monthly arrearage payment that did not include a parenting-time expense
adjustment. We review a decision of a CSM on a motion to modify child support for an
abuse of discretion. Putz v. Putz, 645 N.W.2d 343, 347-48 (Minn. 2002). “A district court
abuses its discretion by making findings of fact that are unsupported by the evidence,
misapplying the law, or delivering a decision that is against logic and the facts on record.”
Woolsey, 975 N.W.2d at 506 (quotation omitted).
An order to pay child-support arrearages is defined by statute to be a “support
order.” Minn. Stat. § 518A.26, subd. 21(a)(2) (2024). A support order “shall specify the
percentage of parenting time granted to or presumed for each parent” for purposes of
calculating the “parenting expense adjustment.” Minn. Stat. § 518A.36, subd. 1(a) (2024).
And when calculating the presumptive child-support obligation, the district court shall
“apply the parenting expense adjustment.” Minn. Stat. § 518A.34(b)(6) (2024). The
parenting expense adjustment “reflects the presumption that while exercising parenting
time, a parent is responsible for and incurs costs of caring for the child.” Minn. Stat.
§ 518A.36, subd. 1(a). But the district court may deviate from the presumptive child-
support obligation, among other reasons, “to encourage prompt and regular payments of
child support and to prevent either parent or the joint children from living in poverty.”
14 Minn. Stat. § 518A.43, subd. 1 (2024). When deviating, the district court must consider
several statutory factors. Id. Most relevant to the issue before us is the first factor, which
requires consideration of “all earnings, income, circumstances, and resources of each
parent, including real and personal property, but excluding income from excess
employment.” Id., subd. 1(1). When a district court decides to deviate from the
presumptive child-support obligation, the district court must make written findings that
address: (1) each parent’s gross income; (2) each parent’s income for determining child
support; (3) the presumptive child-support obligation as calculated pursuant to section
518A.34; (4) the reasons for the deviation; and (5) how the deviation serves the best
interests of the child. Minn. Stat. § 518A.37, subd. 2 (2024).
In her order, the CSM set Rittweger’s monthly arrearage payment amount with “no
credit for parenting time.” The CSM decided not to apply the parenting-time expense
adjustment because Rittweger’s parenting time was “not actually taking place.” In doing
so, the CSM deviated from the presumptive child-support obligation for the arrearages.
Rittweger argues that the CSM abused her discretion by failing to include the
parenting expense adjustment. Rittweger is incorrect. While the CSM was required to
apply the parenting expense adjustment in calculating Rittweger’s presumptive obligation
pursuant to section 518A.34(b)(6), the CSM had the authority to deviate from this
presumption. Minn. Stat. § 518A.43, subd. 1 (authorizing a district court to deviate from
the presumptive child-support obligation after considering certain factors).
Here, the CSM properly deviated from Rittweger’s presumptive obligation when
ordering Rittweger’s monthly arrearage payments. First, the CSM’s order reflects that the
15 CSM considered the required factors. See Minn. Stat. § 518A.43, subd. 1 (listing the
factors that the CSM was required to consider). In her findings of fact, the CSM considered
“Rittweger’s income and expenses” and determined that Rittweger’s obligation without the
parenting expense adjustment would “not cause financial hardship upon [Rittweger] given
his current level of income.” As a result, the CSM did consider Rittweger’s “earnings,
income, circumstances, and resources” and ensured that the order would not impoverish
Rittweger, indicating that the CSM took into consideration the required factors when
deviating from the presumptive obligation. Id.
Further, the CSM made the written findings required by section 518A.37 to support
the deviation from the presumptive obligation. The CSM appended a “Child Support
Guidelines Worksheet” to her order which included the parents’ gross income, income for
determining child support, and Rittweger’s support obligation with the parenting-expense
adjustment applied. See Minn. Stat. § 518A.37, subd. 2 (requiring written findings of each
parent’s income, each parent’s income for determining child support, and the child-support
obligation as computed by section 518A.43). The CSM also specified her reason for
deviating from the presumed obligation, noting that the parenting expense adjustment was
not made because Rittweger’s parenting time was “not actually taking place.” See id.,
subd. 2(4); see also Minn. Stat. § 518A.36, subd. 1(a) (“The parenting expense adjustment
under this section reflects the presumption that while exercising parenting time, a parent is
responsible for and incurs costs of caring for the child.” (emphasis added)). Finally, the
CSM described how the deviation served the best interests of the children, stating that
Rittweger’s failure to make any payments on his child-support obligation had caused the
16 children’s household “financial hardship” and that the deviation would allow for the
payment of Rittweger’s arrearages in a “reasonable time that will benefit the children.” See
Minn. Stat. § 518A.37, subd. 2(5) (requiring written findings describing how the deviation
serves the best interests of the children). As a result, the CSM made the necessary written
findings to support the deviation from Rittweger’s presumed obligation on his arrearages.
In sum, the CSM did not abuse her discretion by declining to apply the parenting-
expense adjustment when ordering Rittweger’s monthly payment on his arrearages.
Affirmed.