State of Iowa, ex rel P.E.M. v. Williams

Opinion

IN THE COURT OF APPEALS OF IOWA

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No. 25-2122

Filed September 2, 2026

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State of Iowa, ex rel. P.E.M., Petitioner–Appellee,

v.

Eddie Earl Williams, Respondent–Appellant,

and

Tayauna Patrice Mosley,

Respondent.

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Appeal from the Iowa District Court for Story County, The Honorable Amy M. Moore, Judge.

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AFFIRMED IN PART, REVERSED IN PART, AND REMANDED WITH INSTRUCTIONS

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Katherine R.J. Scott of New Point Law Firm, PLC, Ames, attorney for appellant.

Brenna Bird, Attorney General, and Justin D. Walker and Brooke J. Thompson, Assistant Attorneys General, attorneys for appellee.

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Considered without oral argument by Tabor, C.J., and Chicchelly and Sandy, JJ.

Opinion by Sandy, J.

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SANDY, Judge.

Eddie Williams appeals the adjustment of his child support obligation for one of his nine children. Williams argues the district court failed to include two qualified additional dependent deductions in its calculation and incorrectly calculated his income. Upon our review, we agree that Williams’s income was incorrectly calculated but find no error in excluding two of his children as qualified additional dependent deductions. Accordingly, we affirm the portion of the district court’s order regarding the qualified additional dependent deductions but reverse and remand for recalculation of Williams’s income consistent with this opinion.

BACKGROUND FACTS AND PROCEEDINGS Williams and Tayauna Mosley are the parents of P.E.M., born in 2017.

Originally, Williams was not required to pay child support. But in 2025, Child Support Services (CSS) reviewed Williams’s case and modified his support obligation to $732 per month plus $263 per month in cash medical support.

The modified support obligation was based on Williams’s gross monthly income, calculated by CSS to be $5,268.18. CSS based their calculations on the financial statement and paychecks Williams submitted. Williams’s financial statement claimed he worked part time as a “cleaning laborer” and was paid bi-weekly. However, the checks Williams provided as proof of his income were based on an irregular schedule and varied significantly in amount. The checks were dated from August to November, and the amounts varied from $250 to $2,000, with no obvious pattern in amount or schedule. Although his monthly income varied, the checks submitted show Williams’s monthly income did not exceed $3,300. Despite the irregularities in Williams’s pay, CSS calculated his income by averaging

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his paychecks and treating that amount as his weekly income rather than bi- weekly income.

Williams’s financial statement also claimed legal responsibility for eight other children, although he was only ordered to pay support for one. The Child Support Guidelines Worksheet completed by CSS credited Williams for four other children in Qualified Additional Dependent Deductions (QADD). In the worksheet’s comments, CSS noted that “Eddie E. Williams requested a qualified additional dependent deduction, however, no verification of paternity was provided, so no deduction could be given.”

Williams requested a hearing on the modification. At the hearing, Williams claimed the CSS calculation was incorrect because it did not include two of his other children as QADDs and because it miscalculated his income as weekly rather than bi-weekly.

Much of the hearing was devoted to sorting out Williams’s income.

Williams testified that before the hearing in December 2025 he worked parttime for his wife’s cleaning business. However, he claimed he no longer worked for his wife since they separated, and he had not worked since November 10. At the time of the hearing, Williams had not attempted to find a new job, and there is nothing in the record indicating he filed for unemployment.

Williams then attempted to clarify his pay schedule and the inconsistent amounts of his paychecks. Williams explained his paychecks were sporadic because he was only paid for a job after his employer was paid. To explain the amounts of his paychecks, Williams testified he was paid a variable percentage of the jobs he worked rather than being compensated

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hourly or by salary. However, Williams did not testify about what his pay rate was or how his pay was calculated.

The conversation then turned to clarifying which of Williams’s children could be included as QADDs. Of the four children excluded from CSS’s deduction, Williams did not have a support order or proof of paternity for three of them. However, Williams filled out a voluntary paternity affidavit for one child, but he had not received anything from the State confirming paternity by the time of the hearing. The one child Williams had a support order for was excluded from the QADD, but his support amount was deducted from Williams’s income calculation.

Ultimately, the district court adopted Williams’s monthly income as calculated by CSS, reasoning:

Eddie provided checks to CSS for verification of his income. Eddie stated that he is paid bi-weekly, however, the checks were dated sporadically from August through November, with no discernible way to determine a regular income amount. Eddie was working for his wife’s residential cleaning business but states it is their slow season and has not worked since early November. He has not sought other employment since last working for his wife. Prior to residential cleaning, he worked on wind turbines for Blattner Energy, making “good money” but he was required to travel often so he left that employment in March of 2025. He testified he has nine children and has a support order for one of those children.

....

The Court is faced with difficulties in determining Eddie’s income based on the provided information. As no further evidence was provided by Eddie, the Court finds CSS’s calculations to be correct and appropriate and will adopt those recommendations. The Court also finds no reason to deviate from the guidelines as they were previously calculated. Those guidelines are the basis for this Order

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Williams appeals, raising the same arguments made during the hearing.

STANDARD OF REVIEW

Review and adjustment of child support obligations are equitable proceedings, so our review is de novo. See Iowa R. App. P. 6.907; State ex rel. Weber v. Denniston, 498 N.W.2d 689, 690 (Iowa 1993).

DISCUSSION

I. Qualified Additional Dependent Deductions

Williams begins by claiming he should have been given additional QADD for two of his other children. “To establish a qualified additional dependent deduction, the requesting parent must demonstrate a legal obligation to the child(ren) under Iowa Code section 252A.3 [(2025)].” Iowa Ct. R. 9.7. According to rule 9.7, there are four ways to establish a legal obligation to a child: (1) by court order; (2) “[b]y the statement of the person admitting paternity in court and upon concurrence of the mother”; (3) “[b]y the filing and registration by the state registrar of an affidavit of paternity”; or (4) by the child’s birth during marriage. Id.

However, there are limitations to when a QADD can be claimed, as “[a] qualified additional dependent deduction cannot be claimed for a child for whom there is a prior court or administrative support order.” Iowa Ct. R. 9.8(2). This is exactly the case for Williams’s child S.W. for whom Williams’s claims should have been included in his deduction. But there is a prior support order for S.W., so Williams cannot claim the child as a QADD.

Williams argues the district court erred in excluding his other child for whom he recently filed a paternity affidavit for, claiming the act of filing the

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affidavit entitled him to the QADD. But Williams had not verified paternity as required by our rules. He had only filed the affidavit. Rule 9.7 requires “the filing and registration by the state registrar of an affidavit of paternity.” Iowa Ct. R. 9.7(3). Williams failed to submit any evidence from the state that he had registered the child. Without some evidence verifying paternity, the district court was correct to exclude P.W. from Williams’s QADD calculation.

Accordingly, the district court was correct to set support without including QADDs for these two children.

II. Income Calculation

Williams’s income proves difficult to calculate for several reasons.

First, it is not clear whether Williams is still employed. Next, despite his claim that he is paid bi-weekly, Williams’s pay schedule is irregular and has no established pattern. Additionally, one of the checks used in calculating Williams’s income was included in error. Williams claimed one of the checks he submitted—dated September 11, 2025, for $1,500—should not have been used in calculating his income because it was for the sale of a vehicle rather than income from his employment. The memo on the check reads “Highlander,” and the State conceded at the hearing that “[p]erhaps that— those funds need to be taken out.” As a final hurdle, the amounts of Williams’s paychecks vary significantly.

While we agree with the district court that there are “difficulties in determining Eddie’s income based on the provided information,” we find that the amount CSS calculated improperly inflated Williams’s income. CSS calculated Williams’s monthly income at $5,268.18, but his paychecks show his monthly income fell somewhere between $2,000 and $3,300. This difference of at least $2,000 between CSS’s calculations and Williams’s

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documentation is clearly erroneous and leaves Williams with a hyperinflated support obligation.

The flaw in CSS’s calculation comes from their treatment of his pay as weekly rather than bi-weekly and the inclusion of the check for the sale of Williams’s vehicle. Given the clear error in the State’s income calculation, we remand the issue to the district court with instructions to calculate Williams’s income on a bi-weekly basis and to exclude the income from the vehicle sale.

AFFIRMED IN PART, REVERSED IN PART, AND REMANDED WITH INSTRUCTIONS.