## Facts

- The parents, Slovak nationals, married and had a daughter (Ivana) in the Slovak Republic.
- The father moved to Maryland; the mother and child remained in Slovakia.
- In a Maryland divorce, the court awarded the mother sole physical custody in Slovakia, gave the father visitation, and ordered him to pay child support without setting a specific amount.
- The father provided money and goods inconsistently; the mother later sought a specific support order in Maryland.
- Evidence showed the father earned about $42,000/year in Maryland and the mother about $5,000/year in Slovakia.
- A master estimated the child’s monthly cost of living in Slovakia at about $275 and, applying Maryland’s income-shares guidelines, recommended $497/month in child support.
- The father objected, arguing the Slovak cost of living was much lower and that paying the guideline amount would be unjust and inappropriate; he also asserted potential Slovak tax consequences.
- The circuit court adopted the recommendation and ordered $497/month without deviation.

## Issues

1. Whether a Maryland court may deviate downward from the Maryland Child Support Guidelines because the child resides in a foreign country with a substantially lower cost of living.
2. Whether speculative foreign tax consequences to the custodial parent can support deviation from the guideline amount.

## Decision

- The Court of Appeals of Maryland affirmed the $497/month support order.
- The court held that a lower cost of living in the child’s foreign residence is not a proper basis to deviate from Maryland’s child-support guidelines.
- The court rejected the father’s foreign tax-consequences argument as speculative and unsupported by evidence.

## Legal Principles

- The guideline amount under Maryland’s Child Support Guidelines is presumptively correct; deviation requires a finding that application would be unjust or inappropriate and must be supported by statutory findings.
- Deviation is tied to child-related needs and parental circumstances recognized by statute; comparative foreign cost-of-living differences are not an authorized basis for downward adjustment.
- Maryland’s income-shares scheme allocates support based on parents’ combined income rather than attempting to recalibrate obligations to local price levels where the child resides.
- A child-support obligor’s claim of adverse foreign tax effects must be supported by evidence; conjecture about foreign law does not justify deviation.

## Conclusion

Maryland’s highest court held that a child’s residence in a lower-cost foreign country does not, by itself, make the guideline support amount unjust or inappropriate; the father therefore remained obligated to pay the guideline-calculated $497 per month.


Gladis v. Gladisova, 382 Md. 654, 856 A.2d 703 (Md. 2004)