McCausland v. McCausland

Facts: The parties were married for over 13 years and had significant assets. In setting support, the court extrapolated from the economic table to determine the amount of child support owed to the children.

Held: The trial court may not use extrapolation in determining Washington State child support obligations. Although the court has discretion to exceed the economic table, it must support the award with written findings of fact based on the parents’ standard of living and the children’s special medical, educational, or financial needs.

Analysis: The court may not use extrapolation because it is merely a mechanical extension of the economic table. RCW 26.19.001 requires the amount of support to be based on the children’s needs, and commensurate with the parents’ income, resources, and standard of living. The court may exceed the economic table, but should first at least consider the Daubert/Rusch factors created by Division One: (1) the parents’ standard of living; and (2) the children’s special medical, educational, or financial needs, and then enter written findings