There are a number of South Carolina family court opinions that are of narrow relevance but of significant importance when relevant. Such cases tend to have a holding on a very small issue but on an issue that recurs frequently. Woodall v. Woodall, 322 S.C. 7, 471 S.E.2d 154 (1996) is one such case.
S.C. Code Regs. § 114-4720(H) (part of South Carolina’s child support regulations) reads, “The cost of day care the parent incurs due to employment or the search for employment, net of the federal income tax credit for such day care, is to be added to the basic obligation.” Aggressive custodial parents who attend college will often try to argue that child care costs incurred so that parent can attend college should be factored into child support pursuant to this subsection. Woodall explicitly rejects this argument, holding,“[b]ecause Wife was a full-time student, her child care costs were not ‘work related’.”
This holding of Woodall is narrow but any attorney defending a child support claim against a college-attending parent best know it.
This is informative and relevant to the times.