In re the Marriage of Cooney

946 P.2d 305, 150 Or. App. 323, 1997 Ore. App. LEXIS 1420
CourtCourt of Appeals of Oregon
DecidedOctober 1, 1997
Docket15-95-07632; CA A93998
StatusPublished
Cited by11 cases

This text of 946 P.2d 305 (In re the Marriage of Cooney) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Marriage of Cooney, 946 P.2d 305, 150 Or. App. 323, 1997 Ore. App. LEXIS 1420 (Or. Ct. App. 1997).

Opinion

EDMONDS, J.

Mother appeals from an order denying her requested relief in a proceeding in which both mother and father sought the amendment of a Nevada dissolution of marriage decree. Father also appeals from the trial court’s denial of his request for an award of attorney fees and costs. We affirm on appeal and cross-appeal.

The parties’ marriage was dissolved by decree in Nevada in 1985. Under the terms of the decree, they shared joint legal custody of their children, but mother was awarded physical care and custody. Father’s child support obligation was set at $200 per month per child. According to the Nevada decree, that amount was to be increased over time as father’s income increased. Father’s child support obligations under the decree terminate when a child reaches the age of 18 years or is otherwise emancipated. Between 1985 and 1995, father’s child support obligations were increased to $500 per month per child by Nevada courts.

In 1995, mother, now an Oregon resident, filed a motion in Lane County Circuit Court seeking modification of the child custody and visitation provision of the Nevada decree. She requested that the court grant her the sole legal and physical custody of the minor children, subject to reasonable visitation, that she be relieved from her obligation to pay transportation costs of the minor children’s visits with father and that father pay her reasonable attorney fees and costs. Father then filed a countermotion, based on ORS 107.135,1 to reduce his child support obligation and to change the requirement of the payment of transportation costs for the children’s visitation. He also requested that mother pay his reasonable attorney fees and costs. At the time, father no longer resided in Nevada but had moved to Tennessee with his present wife.

At the hearing on the motions, father presented evidence that his income had decreased from $75,000 to $50,000 per year. He requested that support be set in accordance with Oregon child support guidelines. The trial court found that [326]*326the reduction in father’s income was not prompted by an attempt to lower his child support obligation, and, applying Oregon child support guidelines, it reduced father’s child support obligation from $1,000 per month to $380 per month. It also ordered mother to pay all uninsured medical, dental, optical and orthodontic expenses incurred on behalf of the parties’ children. Finally, it ruled that it did not have the authority to extend father’s child support obligation beyond the age of 18 because Nevada law terminates child support obligations at that age. It reasoned that the Full Faith and Credit Clause of the United States Constitution2 prevented it from extending the obligation to age 21 as authorized by Oregon law. See ORS 107.108. Mother appeals from those rulings.

We turn first to the trial court’s refusal to extend father’s child support obligations to age 21. Mother first argues that, because neither of the parties resided in Nevada at the time of the hearing and because both had submitted to the jurisdiction of the Oregon courts by filing motions in Oregon seeking modification of the Nevada judgment, the Full Faith and Credit Clause is not an impediment to extending the support obligations. She contends that the issue is governed by ORS chapter 107. However, ORS chapter 107 contains no authority for Oregon courts to modify foreign child support judgments. Rather, that authority is found in ORS chapter 110, also known as the Uniform Interstate Family Support Act (UIFSA).3

[327]*327Next, mother asserts that because father filed his motion under ORS 107.135, ORS chapter 110 is inapplicable. We disagree. The fact that father cited the wrong statute as the authority for his motion does not preclude us from deciding the issue under the correct statute, in the absence of an issue about preservation. See ORAP 5.45(2). Here, the trial court’s decision was not impeded by the erroneous citation of the authority on which father relied in support of his motion, and the trial court’s decision was authorized by ORS 110.432(2).

Mother’s counsel also suggested in oral argument that ORS chapter 110 applies only when the state is involved in an enforcement proceeding. However, ORS 110.426 provides:

“A party or support enforcement agency seeking to modify, or to modify and enforce, a child support order issued in another state shall register that order in this state in the same manner provided in ORS 110.405 to 110.411 if the order has not been registered. A petition for modification may be filed at the same time as a request for registration, or later. The pleading must specify the grounds for modification.” (Emphasis supplied.)

Thus, even when the state is not a party and enforcement is not at issue, as is the case here, ORS chapter 110 applies to modifications of foreign child support orders.

Under ORS chapter 110, the trial court correctly held that it did not have the authority to extend the duration of the child support orders beyond the age of 18. ORS 110.432(3) provides:

“A tribunal of this state may not modify any aspect of a child support order that may not be modified under the law of the issuing state.”

The commentary to UIFSA further explains:

[328]*328“[ORS 110.432(3)] prevents the modification of any final, nonmodifiable aspect of the original order. For example, if child support was ordered through age 21 in accordance with the law of the issuing state and the law of the forum state ends the support obligation at 18, modification by the forum tribunal may not affect the duration of the support order to age 21.” Commentary, Uniform Interstate Family Support Act, § 611 (1992). (Emphasis supplied.)

Nevada law terminates child support at age 18. Thus, an Oregon court could not extend a Nevada child support obligation to age 21. Accordingly, the trial court did not err when it refused mother’s request to award support beyond the age of 18.

Mother also contends that father’s support obligation should have been calculated under Nevada child support guidelines. However, ORS 110.432(2) provides:

“Modification of a registered child support order is subject to the same requirements, procedures and defenses that apply to the modification of an order issued by a tribunal of this state and the order may be enforced and satisfied in the same manner.”

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Bluebook (online)
946 P.2d 305, 150 Or. App. 323, 1997 Ore. App. LEXIS 1420, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-marriage-of-cooney-orctapp-1997.