## Facts

- Peter R. Ciampa and Cynthia L. Ciampa divorced after a marriage that produced three daughters; Cynthia was the residential custodian.
- A 2008 supplemental decree incorporated an agreement requiring Peter to pay $6,000 per month in child support for three children.
- In 2010, after the oldest child turned 18, the family court kept support at $6,000 per month, supported by detailed findings on the remaining minor children’s reasonable expenses.
- In 2012, anticipating the second child turning 18, Peter moved to modify support to reflect that only one minor child remained.
- Evidence at the 2012 hearing included Cynthia’s claim that the remaining child’s monthly expenses exceeded $9,000.
- The family court found the remaining minor child’s reasonable monthly living expenses to be $6,617 and reduced support to $5,800 per month.
- The parents’ combined income exceeded the maximum covered by Kentucky’s child-support guidelines; Peter’s earnings were very high relative to Cynthia’s.
- After post-judgment motions, the family court entered additional findings but declined to reduce support below $5,800 per month.

## Issues

1. Whether the family court abused its discretion by ordering $5,800 per month in child support for one minor child in an above-guidelines, high-income case.
2. Whether the family court’s written findings sufficiently justified the amount as a deviation from the guideline framework and were supported by substantial evidence.

## Decision

- The Court of Appeals affirmed the order setting child support at $5,800 per month.
- The court held the family court did not abuse its discretion in an above-guidelines case where it tied the award to the child’s reasonable needs and the parents’ resources.
- The court concluded the family court’s detailed written findings adequately justified the deviation and were supported by substantial evidence.

## Legal Principles

- When combined parental income exceeds the upper limit of the statutory guideline tables, the trial court has broad discretion to set child support.
- In above-guidelines cases, the support amount must be grounded in the child’s reasonable needs in light of the parents’ financial abilities and the family’s prior standard of living.
- A deviation from guideline calculations in an above-guidelines case must be justified by written findings explaining the factual basis for the award.
- Appellate review of child-support awards is for abuse of discretion; fact findings supported by substantial evidence are not disturbed on appeal.

## Conclusion

The court upheld a high child-support award for a single remaining minor child because the family court made detailed, evidence-based written findings on the child’s reasonable expenses and the parents’ financial circumstances, satisfying Kentucky’s requirements for above-guidelines support and falling within the trial court’s discretion.


Ciampa v. Ciampa, 415 S.W.3d 97 (Ky. Ct. App. 2013)