## Facts

- A marriage of approximately 18 years was dissolved; the parties had twins, and the wife served primarily as a stay-at-home parent.
- The husband worked in global equity markets and earned more than $1 million annually, with a base salary around $200,000 and highly variable cash and stock bonuses.
- The marital estate was approximately $18 million, including substantial equity compensation (e.g., options and restricted stock).
- The trial court ordered weekly child support at the maximum guideline amount, plus supplemental child support equal to 20% of the husband’s annual net cash bonus.
- The trial court also ordered additional alimony and child support equal to 20% of any future state and federal tax refunds, along with other financial and property orders, including awarding the wife approximately $10.65 million in assets and a mortgage-free residence valued around $2.55 million.
- The trial court stated it departed from the guidelines based on the husband’s extraordinary resources and the wife’s need to provide a home for the children.

## Issues

1. Whether ordering open-ended supplemental child support equal to 20% of the obligor’s future net cash bonuses applied the correct legal standard under Connecticut’s child support statutes and guidelines.
2. Whether ordering payment of 20% of future state and federal tax refunds as additional alimony and child support was permissible.
3. Whether the distribution of marital assets and related financial orders constituted an abuse of discretion.

## Decision

- The Supreme Court affirmed in part and reversed in part.
- The Court held the trial court applied an improper standard and abused its discretion by ordering supplemental child support equal to 20% of the husband’s net cash bonus without grounding the percentage in the guideline framework and the children’s reasonable needs.
- The Court held the order requiring payment of 20% of future tax refunds as additional alimony and child support was improper under the statutory and guideline scheme.
- The Court largely upheld the property distribution and other financial orders, concluding they fell within the trial court’s broad discretion.
- The case was remanded for recalculation and entry of new child-support-related orders consistent with the opinion.

## Legal Principles

- Connecticut child support guidelines apply in all cases; when combined net income exceeds the schedule’s upper limit, the guideline percentages remain a benchmark to preserve consistency and equity.
- The presumptive percentage of net income devoted to child support declines as income rises; for two children at the top of the schedule ($4,000 combined net weekly income), the schedule percentage is 15.89%.
- Courts may include bonus income and may enter supplemental support orders tied to future bonuses, but the percentage generally should be consistent with the guideline percentages unless a deviation is justified by recognized deviation criteria and supported by required findings.
- Even for very high earners, child support must remain tied to the children’s actual, reasonable needs; an obligor should pay a fair share of what is necessary to maintain a reasonable standard of living, not an unlimited share of fluctuating income.
- Treating tax refunds as a separate, open-ended source for additional support is improper when it functions as an untethered surcharge rather than being addressed within a guideline-based income analysis and properly supported deviation findings.

## Conclusion

The court required that high-income child support remain anchored to the guideline framework and children’s reasonable needs, reversing open-ended percentage awards based on bonuses and tax refunds while leaving the broader property and related financial orders intact and remanding for recalculation consistent with those constraints.


Maturo v. Maturo, 296 Conn. 80 (2010)