## Facts

- Emilio Estevez and Carey L. Salley, parents of two minor children, had a prior court-approved child support agreement requiring Estevez to pay $3,500 per month plus the children’s medical expenses.
- Estevez also voluntarily paid substantial additional expenses (including childcare, private school, vacations, and a housekeeper), and his parents provided a residence for Salley and the children.
- Salley sought a modification of child support and served extensive document demands seeking detailed information about Estevez’s income, expenses, and assets to calculate guideline support.
- Estevez stipulated his annual gross income was not less than approximately $1.4 million, which would yield a presumptive guideline support figure far above the existing court-ordered amount, and stated he would comply with any reasonable court-ordered support.
- Estevez argued that detailed discovery into his net worth and lifestyle was irrelevant and unduly intrusive because his ability to pay was not in dispute.
- The superior court narrowed but granted Salley’s motion to compel production of financial documents.
- Estevez petitioned for a writ of mandate to vacate the discovery order.

## Issues

1. Whether post-1992 guideline child support statutes require detailed financial discovery in all cases, thereby displacing the rule permitting a court to preclude net-worth and lifestyle discovery when ability to pay is undisputed.
2. Whether a high-income obligor’s stipulation to an income level sufficient to support any reasonable order can make extensive financial discovery irrelevant and improper in a child-support modification proceeding.

## Decision

- The Court of Appeal granted the writ petition.
- The court held that the later guideline statutes did not abrogate the rule allowing trial courts to preclude discovery into a noncustodial parent’s net worth and lifestyle when ability to pay any reasonable support order is not in question.
- The court directed the superior court to vacate its order compelling production of the requested financial documents.

## Legal Principles

- Trial courts may preclude or sharply limit discovery into an obligor’s net worth and lifestyle when the obligor’s ability to pay any reasonable support order is not genuinely disputed.
- Enactment of statewide guideline child support and a rebuttable presumption favoring guideline amounts does not, by itself, create an automatic entitlement to intrusive discovery where the information sought is marginally relevant.
- In extraordinary high-income cases, a sufficiently robust income stipulation may satisfy the information needed for guideline calculation and related determinations, reducing the relevance of further detailed financial documentation.
- Discovery orders must account for relevance, burden, and privacy interests; courts may prevent proceedings from devolving into lifestyle-focused financial probing when the probative value is low.

## Conclusion

The court concluded that California’s guideline child support statutes left intact the discretionary power to limit intrusive financial discovery in extraordinary high-income cases where the obligor stipulates to an income level sufficient to support any reasonable order, and it ordered the trial court to vacate the compelled-discovery order.


Estevez v. Superior Court, 27 Cal. Rptr. 2d 470 (Cal. Ct. App. 1994)