## Facts

- Andrea Zabloski and Daryl Hall had a single sexual encounter in early 1983; they were never married and never lived together.
- Their son was born on January 8, 1984; he was healthy, developing normally, and had no special medical or educational needs.
- Zabloski, the custodial parent in Duluth, received public assistance for several years and lived with her children in a small apartment.
- Hall, the noncustodial parent, had extremely high net income (approximately $1.4 million annually) and expressed a desire that the child be raised without extravagant expenditures.
- After Hall acknowledged paternity, the dispute centered on the amount of child support and related financial obligations.
- Zabloski sought support substantially above guideline levels, submitting a proposed budget that included housing and vehicle upgrades and high-cost child expenditures (including a piano and other discretionary items).
- Expert testimony indicated that spending on children varies widely by parental preference and is not strictly determined by objective necessity.

## Issues

1. Whether a court may order child support above the statutory guideline maximum based solely on the obligor parent’s extraordinary income when the child is normal and has no special needs.
2. Whether the district court abused its discretion by declining to deviate upward from the guideline amount and limiting support to the guideline maximum plus comprehensive medical coverage.

## Decision

- The Minnesota Court of Appeals affirmed the district court’s order.
- The court held the district court did not abuse its discretion by setting support at the guideline maximum for one child ($1,000 per month) despite Hall’s substantial income.
- The court upheld requirements that Hall provide health and dental insurance and pay uninsured medical and dental expenses.
- The court rejected the claim that the child was legally entitled, by court order, to a materially higher standard of living based only on Hall’s wealth.

## Legal Principles

- Statutory child-support guidelines are intended to cover the reasonable needs of normal children and account for parental income; placement in the highest guideline bracket does not require automatic increases beyond the guideline maximum.
- Upward deviation from guidelines requires specific findings showing why the guideline amount is inadequate under the statutory factors.
- Extraordinary obligor income, without evidence that the guideline amount fails to meet the child’s reasonable needs, does not by itself justify an upward deviation.
- Child-support determinations and deviation decisions are reviewed for abuse of discretion and receive substantial appellate deference when supported by findings and the record.

## Conclusion

The court affirmed a guideline-maximum child-support award plus full medical and dental responsibility for a healthy, normal child, holding that the obligor’s extreme wealth alone did not require an upward deviation absent proof that the guideline amount was inadequate to meet the child’s reasonable needs.


Zabloski v. Hall, 418 N.W.2d 187 (Minn. Ct. App. 1988)