P.O. v. J.S. (Child Support)
Hawaii Supreme Court, April 6, 2017.
Hawaii law requires that the Family Court (or Office of Child Support Hearings) utilize the Child Support Guidelines Worksheet (“CSGW”), any time that child support is ordered, even when the court finds an exceptional circumstance. This requirement is all over the HRS , and the State means it. An order entered without a filed CSGW can be set aside.
“We also hold that the family court is required by multiple provisions
of the Hawaii Revised Statutes to use the Hawaiʻi Child Support Guidelines when it
reviews the merits of a request for adjustment of a monthly support obligation.”