## Facts

- Joyce E. Childers (wife) and Leland E. Childers (husband), a solo-practice physician, married in 1953 and had three sons (born 1954, 1956, 1959).
- In the dissolution decree, the trial court awarded the wife custody and ordered the husband to pay:
  - Child support for the sons “while they attend college,” potentially extending to approximately age 22.
  - Educational expenses (tuition, books, and related fees) for each son.
  - Maintenance to the wife while she pursued a baccalaureate degree (not contested on review).
  - Medical and dental insurance for the wife and sons until the sons were no longer dependent.
- The husband appealed; the Court of Appeals reversed the decree only to the extent it required support beyond age 18, reasoning a parent has no duty to support an adult child and that imposing such an obligation on divorced parents violated state privileges and immunities and federal equal protection.
- The Washington Supreme Court granted review; the only issue remaining was the validity of post-majority support for the sons’ college education.

## Issues

1. In a dissolution proceeding, may a court require a parent to support a child beyond the age of majority while the child pursues a college education?
2. If such authority exists, does permitting post-majority educational support orders in dissolution cases violate equal protection or the Washington privileges and immunities clause because comparable obligations are not judicially imposed on married parents?

## Decision

- The Washington Supreme Court held that, within the trial court’s sound discretion, a court may order post-majority support while a child pursues a college education.
- The court concluded the Dissolution Act’s child-support provisions authorize educational support beyond age 18 when tied to the child’s needs and welfare.
- The court rejected the constitutional challenges, holding the dissolution context provides a rational basis for judicially allocating parental financial obligations in ways not imposed on intact families.
- The court reversed the Court of Appeals in part and reinstated the trial court’s post-majority college-support provisions.

## Legal Principles

- Washington dissolution courts have broad statutory authority to enter child-support orders that are just and serve the children’s best interests; that authority may extend beyond the age of majority to meet educational needs.
- Post-majority educational support may be treated as “child support” when the child remains dependent and the support is limited to attendance in higher education rather than indefinite adult maintenance.
- Trial courts possess wide discretion to set support based on the children’s needs and the parents’ financial ability; appellate review is for abuse of discretion.
- Imposing post-majority educational support in dissolution proceedings does not violate equal protection or state privileges and immunities because the state may rationally treat dissolution cases differently from intact marriages when it must judicially restructure family obligations.

## Conclusion

The court upheld trial-court authority in dissolution proceedings to order financially able parents to contribute to dependent children’s college expenses beyond age 18, and it held that limiting such enforceable obligations to dissolution cases is constitutionally permissible.


Childers v. Childers, 575 P.2d 201 (Wash. 1978)