Kay Cooley v. Aaron Cooley

CourtCourt of Appeals of Iowa
DecidedOctober 6, 2021
Docket20-1501
StatusPublished

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

Bluebook
Kay Cooley v. Aaron Cooley, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-1501 Filed October 6, 2021

IN RE THE MARRIAGE OF KAY COOLEY AND AARON COOLEY

Upon the Petition of KAY COOLEY, Petitioner-Appellee,

And Concerning AARON COOLEY, Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Butler County, Chris Foy, Judge.

Aaron Cooley appeals both the temporary support order established in

marriage dissolution and the denial of his subsequent motion for amended and

expanded findings and conclusions of law. AFFIRMED AS MODIFED AND

REMANDED.

Maria L. Hartman of Sweet & Hartman, P.L.C., Reinbeck, for appellant.

Elizabeth M. Wayne of Papenheim Law Office, Parkersburg, for appellee.

Considered by Vaitheswaran, P.J., and Greer and Schumacher, JJ. 2

GREER, Judge.

After an order established temporary child support and spousal support,

Aaron Cooley appeals arguing the district court’s decision required that he work

overtime to satisfy the award and that it was unfair to him in several respects.

Aaron asserts the district court erred by averaging his income to calculate his child-

support obligation; awarding support greater than the guideline amount; failing to

properly determine the health-insurance obligations for the minor child; requiring

him to pay health expenses for his adult child; and requiring him to pay Kay

Cooley’s health insurance and medical expenses on top of the spousal-support

award. Kay requests appellate attorney fees, and Aaron argues each should pay

their own fees.

I. Facts and Prior Proceedings.

Kay and Aaron were married in 2000. They have two children. The

youngest, M.C., is still a minor, while the older son is an adult attending college.

Aaron works as a service manager at ThermoKing in Cedar Falls and has since

2019. Kay works as an educational aide for the Aplington-Parkersburg Community

School District. Kay’s undisputed gross annual income is $15,120. Aaron’s

current annual pre-tax income is $62,400, excluding any overtime.

Kay filed for divorce in June 2020. She filed a separate application seeking

temporary physical care, child support, spousal support, and attorney fees.

Because of the COVID-19 pandemic, there was no in-person testimony, only

exhibits and affidavits. Both parties supplied pay stubs. Aaron’s paystub showed

that he pays $678.67 per month in health, vision, and dental insurance for the

family. 3

The court issued a temporary support order providing Aaron and Kay would

share joint legal custody of M.C. but granting Kay physical care during the divorce

proceedings. The court determined Aaron “is capable of providing appropriate

care and supervision for M.C., and he should have regular visitation to maintain

the bond between the two.” The court then took Aaron’s and Kay’s average

incomes over the past three years to determine the income of each parent for

purposes of calculating child support.1 Aaron’s annual income was calculated to

be $70,160. This three-year average included the income that Aaron earned with

his previous employer. Aaron’s income was not adjusted to reflect a health

insurance deduction as allowed by Iowa Court Rule 9.14(5).

Aaron was made responsible for maintaining health and dental insurance

for Kay, M.C., and their adult child, as well as paying 100% of any uncovered

medical or dental expenses for all three. He was also instructed to pay both

temporary child and spousal support and attorney fees. The child-support

guidelines determined that Aaron should pay $756 per month to Kay for care of

M.C. In the beginning of the order, the district court stated it would follow the

guidelines and honor this amount. However, the order ultimately required Aaron

to pay $831 per month without explanation concerning the increase over the

guideline amount.

Aaron filed a motion for amended and expanded findings and conclusions

of law questioning the use of his average income, the lack of health-insurance

deduction, and the requirement that he pay all of Kay’s and M.C.’s uncovered

1 Neither party requested that their child-support obligation be calculated this way. 4

medical expenses.2 Kay resisted. She argued that Aaron was on track, using his

annualized income and including overtime pay, to earn more than the averaged

amount. She also argued that Aaron was not entitled to the health-insurance

deduction because he did not provide adequate information to determine what that

deduction would be. Kay also believed the uncovered medical expenses were

appropriately assigned to Aaron because he has a Health Savings Account

(“HSA”) for such expenses. The court denied the motion, citing only the reasons

provided in Kay’s resistance. Aaron appeals.

II. Standard of Review.

A temporary support order is final and reviewable. In re Marriage of Denly,

590 N.W.2d 48, 50 (Iowa 1999). A dissolution of marriage action is an equitable

proceeding, and we review de novo. In re Marriage of Olson, No. 18-1860, 2019

WL 4302128, at *1 (Iowa Ct. App. Sept. 11, 2019); Iowa R. App. P. 6.907. “We

examine the entire record and determine anew the issues properly presented.” In

re Marriage of Edwards, No. 19-1786, 2020 WL 3564698, at *2 (Iowa Ct. App. July

1, 2020). “We give weight to the findings of the district court, particularly

concerning the credibility of witnesses; however, those findings are not binding

upon us.” In re Marriage of McDermott, 827 N.W.2d 671, 676 (Iowa 2013).

III. Discussion.

Aaron presents six issues on appeal: the district court’s use of his averaged

income to calculate his child-support obligation, the deviation from the child

support guidelines, the lack of health-insurance deduction, his responsibility for all

2There were other issues raised in this motion, but they are not relevant to this appeal. 5

uncovered medical expenses for his minor child, his responsibility for medical

insurance and uncovered expenses for their adult child, and his responsibility for

medical insurance and uncovered expenses for Kay over and above the spousal-

support obligation. We take each in turn.

A. Aaron’s income.

Aaron argues that the district court was wrong to average his income from

the past three years to determine his current income for child-support purposes.

We agree. Having said that, from the paystubs presented by Aaron, there is

support for the district court’s determination that Aaron would earn around $70,160

annually. To determine child and spousal support, courts calculate both party’s

net monthly income by taking their gross monthly income and factoring in

specifically enumerated deductions. In re Marriage of Powell, 474 N.W.2d 531,

532 (Iowa 1991). Courts average income when the earnings of one of the parties

fluctuates substantially. See In re Marriage of Knickerbocker, 601 N.W.2d 48, 51

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