FANCHER v. MCDOWELL

CourtCourt of Civil Appeals of Oklahoma
DecidedJune 5, 2026
Docket122083
StatusPublished

This text of FANCHER v. MCDOWELL (FANCHER v. MCDOWELL) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
FANCHER v. MCDOWELL, (Okla. Ct. App. 2026).

Opinion

OSCN Found Document:FANCHER v. MCDOWELL

FANCHER v. MCDOWELL
2026 OK CIV APP 21
Case Number: 122083
Decided: 06/05/2026
Mandate Issued: 07/02/2026
COURT OF CIVIL APPEALS OF THE STATE OF OKLAHOMA, DIVISION II


Cite as: 2026 OK CIV APP 21, __ P.3d __


EVA MARIE FANCHER, Petitioner/Appellant,
vs.
PETER CHRISTOPHER MCDOWELL, Respondent/Appellee.

APPEAL FROM THE DISTRICT COURT OF
CANADIAN COUNTY, OKLAHOMA

HONORABLE BARBARA HATFIELD, TRIAL JUDGE

REVERSED IN PART AND REMANDED FOR FURTHER PROCEEDINGS, AFFIRMED IN PART

Steven M. Ditto, STEVEN M. DITTO, P.C., Oklahoma City, Oklahoma for Petitioner/Appellant

Tammy S. Boling, ATTORNEY AT LAW, El Reno, Oklahoma

Jana L. Knott, Allyson A. Stewart, BASS LAW, Oklahoma City, Oklahoma for Defendant/Appellee

JOHN F. FISCHER, JUDGE:

¶1 Eva Marie Fancher (Mother) appeals the district court's amended order modifying Peter Christopher McDowell's (Father) monthly child support obligation, along with the order awarding her only a portion of her requested award of attorney fees and costs. Because the district court failed to consider the proper factors for determining the amount of Father's child support where his income exceeded the maximum amount indicated by the child support guidelines, we reverse this order and remand for further proceedings consistent with this Opinion. However, the order awarding Mother a portion of her requested attorney fees and costs is affirmed because she has not shown an abuse of discretion occurred.

BACKGROUND

¶2 Mother and Father are the parents of two minor children. Though they were never married, they once lived together. During that time, Father made approximately $160,000 a year, and Mother stayed home with the children. After they separated in 2010, the district court's docket shows a decree of paternity was entered in Texas, which was then registered as a foreign decree in Oklahoma.

¶3 As pertinent to this appeal, the district court entered an agreed order in 2021, awarding Mother sole custody of the children and Father supervised visitation. Pursuant to the 2021 order, Father was ordered to pay monthly child support in the amount of around $720 based on his then gross income of approximately $3,600 a month. The 2021 order contained a provision requiring each party to notify the other within seven days if one party obtained employment earning renumeration of more than 25% of their current incomes. The order included instructions for new child support guidelines to be prepared by Mother's attorney for submission to the court without necessitating her filing another motion to modify.

¶4 When Father failed to provide this timely notice, Mother filed another motion to modify in 2022, alleging Father's income had increased by over 25% and seeking a modification of child support. A discovery dispute ensued regarding Father's income, complicated by him frequently changing attorneys, though some of the changes were due to his attorney becoming ill but then recovering and reentering the case. Father also changed jobs two times after Mother filed her motion, each time increasing his income by over 25%. Ultimately, his gross income was more than $26,000 a month. This amount was significantly above $15,000, which is the maximum combined gross monthly income amount listed in the child support guidelines. A two-day hearing was held on Mother's motion in August 2023 and December 2023.

¶5 At the hearing, Mother presented evidence of the children's direct and indirect monthly living expenses and asserted that Father's percentage of these expenses was approximately $4,055 a month, requesting child support in this amount. Mother testified that the standard of living she provided the children based on these expenses was in their best interests. Mother further testified that her gross monthly income was approximately $4,300 but that this was not enough to cover her and the children's monthly expenses.

¶6 Father testified that he did not believe the children's expenses were as much as Mother asserted. He testified that he thought a reasonable amount of the children's expenses was around $1,700 a month, which is approximately the same amount he would be required to pay applying his percentage share of the parents' combined income to the maximum combined income amount listed in the guidelines. Father did not provide a specific calculation as to how he arrived at this amount but simply thought it sounded reasonable. Moreover, the parties' testimony indicated that Father lacked personal knowledge of the children's expenses, such as their food costs, given he had no overnight visits and had only seen them once in the three-year period before the hearing. Regardless, towards the end of his testimony, Father stated that he would "offer" to pay a monthly amount of $2,250.

¶7 The district court then ordered Father to pay $2,250 in monthly child support based on this amount he volunteered to pay, noting it was not following Archer v. Archer, 1991 OK CIV APP 28813 P.2d 1059

¶8 Mother then filed an application for attorney fees and costs seeking a total amount of $14,185.95 incurred during the approximately two years it took to reach a resolution on her motion to modify. At the hearing on her application, Mother emphasized Father's delays during the pendency of the case. She noted that the litigation could have been avoided or limited if Father had complied with the provision in the 2021 order requiring him to timely notify her of a significant change to his income so that her attorney could draft a new child support calculation for submission to the court. Mother also argued that Father was the party with the greater ability to pay. Father made various arguments against Mother's request, including that she had declined his offers to settle the case and that she could have increased her income if she returned to practicing law as opposed to teaching school.

¶9 The district court concluded that the amount of Mother's requested fees was reasonable. However, the court stated it was only awarding her fees and costs incurred for her discovery efforts, noting the discovery "really was quite out of line from the norm." The court did not award Mother any other fees or costs without elaborating on the reason for this decision. Eventually, the district court entered an order awarding Mother attorney fees and costs of $4,099.31.

¶10 Mother appeals the order awarding her child support in the amount of $2,250 a month and the order awarding her fees and costs in the amount of $4,099.31.

STANDARD OF REVIEW

¶11 The district court's decision on a motion to modify child support will not be disturbed unless the "court's decision is clearly against the weight of the evidence so as to constitute an abuse of discretion." Williamson v. Williamson, 2005 OK 6107 P.3d 589

¶12 Regarding an award of attorney fees and costs, each party ordinarily bears the cost of her legal representation, and courts are without authority to award attorney fees and costs in the absence of a specific statute or specific agreement between the parties. Metcalf v. Metcalf, 2020 OK 20465 P.3d 1187See McKiddy v. Alarkon, 2011 OK CIV APP 63254 P.3d 141See also Childers v. Childers, 2016 OK 95

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Bluebook (online)
FANCHER v. MCDOWELL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fancher-v-mcdowell-oklacivapp-2026.