## Facts

- Kimberly Ann Beck (mother) and Richard H. Beck, Jr. (father) divorced in 2001; the mother received legal and primary physical custody of the parties’ two minor children.
- The divorce judgment set the father’s child-support obligation at $608.45 per month.
- In 2004, the father moved to modify child support; the mother responded and sought an increase.
- At the modification hearing, each party had a child from a prior relationship living in their respective households; the father’s in-home child was a half-sibling of the parties’ children.
- The father also had a later-born child for whom he paid $300 per month in child support.
- The circuit court calculated the presumptive guideline amount for the parties’ two children as $816.17 per month.
- The circuit court nevertheless ordered $700 per month, stating the downward deviation was based on the father’s in-home half-sibling child and the court’s view that it benefited the parties’ children for that half-sibling to be supported.
- The mother appealed, arguing the deviation was statutorily barred because it was based solely on the presence of another child in the father’s household.

## Issues

1. Whether Maryland Family Law Article § 12-202(a)(2)(iv) permits a downward deviation from guideline child support based solely on the presence of another child living in the obligor’s household when the deviation is not supported by any other stated basis.

## Decision

- The appellate court reversed the downward deviation and remanded.
- The court held that the circuit court’s stated reason—supporting the father’s in-home half-sibling child—was legally insufficient as a sole basis to depart downward from the presumptive guideline amount.
- The case was remanded for further proceedings consistent with the opinion, including application of the guideline amount or entry of a deviation supported by legally permissible, articulated findings.

## Legal Principles

- Maryland’s child-support guidelines amount is presumptively correct; deviation is allowed only if application of the guidelines would be unjust or inappropriate and the court states supporting facts on the record.
- Under F.L. § 12-202(a)(2)(iv), a departure from the guidelines may not be based solely on the presence in a parent’s household of other children to whom that parent owes no duty of support.
- A trial court abuses its discretion when it departs from the guidelines based on a factor the statute forbids as the sole ground for deviation.
- Any deviation must be tied to statutorily authorized considerations and supported by explicit findings beyond a prohibited single factor.

## Conclusion

The appellate court held that a trial court may not reduce presumptive guideline child support solely because the obligor is raising another child in the household; absent additional legally sufficient findings, the guideline amount controls, and the matter must be reconsidered on remand.


Beck v. Beck, 165 Md. App. 445, 885 A.2d 887 (Md. Ct. Spec. App. 2005)