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Joel Cain, Appellant-Petitioner v. Tunishia Martin-Cain, Appellee-Respondent
MEMORANDUM DECISION
Case Summary
[1] Joel Cain (“Father”) appeals the trial court's post-dissolution order modifying parenting time and child support. Tunishia Martin-Cain (“Mother”) (now Tunishia Martin-Jennings) cross-appeals, arguing that the trial court erred in crediting Father for overpayment of child support. Finding that the court did not err in modifying Father's parenting time but erred in its modification of child support and in crediting Father for overpayment, we affirm in part, reverse in part, and remand.
Facts and Procedural History
[2] Father and Mother have two children together: Ch.C., born in 2012, and Ca.C., born in 2014. Father and Mother married in 2018. That same year, Father began working as a patrol officer with the Indianapolis Metropolitan Police Department (IMPD). His work schedule consisted of six consecutive days on duty followed by three days off. Also in 2018, Mother obtained her real-estate license and began selling homes for a real-estate agency.
[3] Mother filed for divorce in May 2019, and the marriage was dissolved by settlement agreement that September. At that time, the children were 7 and 5 years old. Under the agreement, Mother and Father were granted joint legal custody, Mother was granted primary physical custody, and Father was granted parenting time based on his work schedule as follows: “[Mother] shall have the children for six (6) consecutive overnights followed by [Father] having parenting time with the children for three (3) consecutive overnights when he is not working․ The 6/3 rotation between the parties shall continue year round, including summer break ․” Appellant's App. Vol. 2 p. 43. The agreement also provided that Father had a child-support arrearage of $2,142 as of August 2019 and would “pay the arrearage amount at the rate of $22 per week until paid in full.” Id. at 44. Father was ordered to pay Mother a total of $175 per week by income-withholding order—$22 for the arrearage plus $153 in child support.
[4] Mother remarried, and she and her husband had a child together in 2020. In 2022, Mother got a job at Progressive Insurance with an annual salary of $50,000. The following year, she and her husband had another child but “couldn't find childcare,” so she quit Progressive. Tr. Vol. 2 p. 16. When Mother quit, her husband “picked up a better job making more income so [she] could be available” for all four children. Id. at 54. After that, Mother opened an in-home daycare, but that lasted only a few months. Later in 2023, Mother went back to working as a realtor. The most she made in a year in commissions from real-estate sales was around $40,000.
[5] As for Father, in 2023, he was in an accident during a high-speed chase and broke his femur, leaving him unable to work for around nine months. In March 2024, three weeks after returning to work, he was shot in the line of duty. For about six months after the shooting, Father was “on a light duty status” and couldn't work overtime or additional part-time work. Id. at 91. Once he was cleared to resume normal work, he picked up overtime shifts and part-time jobs outside of IMPD so he could save for a new car and house and pay off debts incurred while he was unable to work. Father worked part time as a school resource officer for Lawrence Township and for a security company.
[6] In February 2025, Mother moved to modify parenting time and child support.1 She claimed that Father had secured additional employment, which resulted in an increase in income and “affect[ed] his ability to be present during his parenting time with the children.” Appellant's App. Vol. 2 p. 39. The parties participated in mediation in May, but it was unsuccessful.
[7] The trial court held a hearing on Mother's motion in September. By then, Ch.C. was 13, Ca.C. was 11, and Mother's two other children were 5 and 2. Mother requested that Father's parenting time be modified consistent with the Indiana Parenting Time Guidelines, meaning he would have Ch.C. and Ca.C. for one night a week, every other weekend, and holidays, with extended time in the summer. Mother testified that because Father's parenting time fell on different days each week, the children struggled to maintain a routine or structure and to participate in extracurricular activities. For example, Ca.C. had previously played soccer, but he wasn't playing that year because he'd missed tryouts, which had been during Father's parenting time. Mother claimed there'd been “so much confusion” about scheduling that Father had “sent emails and texts unsure if he gets the kids those days.” Tr. p. 16. She provided evidence of text messages with Father reflecting confusion about parenting-time days. Additionally, there were times when Father had to drop the children off early in the morning before he went to work. Mother provided text messages from a day when Father had to drop Ca.C. off at 4:30 a.m. on a school day, which was especially concerning because Ca.C.’s teacher had previously reported to Mother and Father that he'd been falling asleep in class. Mother opined that Father having parenting time consistent with the guidelines would be best for the children because it would allow them to be more consistent in their extracurricular activities and develop their social lives.
[8] As for child support, although Father's base salary from IMPD was $86,781, Mother's proposed obligation worksheet listed his weekly gross income as $4,651.81, which comes out to an annual income of $241,894.12 ($4,651.81 x 52 weeks). Mother included $290 as her weekly gross income, which amounts to an annual income of $15,080. Based on these figures, Father's support obligation came out to $548 a week. Mother testified that she did hair at her home salon and worked part time as a yoga instructor. She estimated that she made around $290 a week from these jobs, “but [her] husband covers the finances.” Id. at 38. Mother explained that the proposed amount for Father's weekly gross income encompassed both his IMPD overtime and part-time earnings, and she “believe[d]” this number was “based on [20]24 and [20]25.” Id. at 53. She submitted evidence of one of Father's IMPD pay stubs from 2025 as well as his 2024 tax documents, which showed a total of $149,114 in wages from IMPD, Lawrence Township, and the security company for that year. See Exs. 11, 13.
[9] Father, who remarried in May 2025, testified that he still worked six days on duty followed by three days off, and his hours were 5:30 a.m. to 1:30 p.m. He explained that he'd “accelerated [his] part-time activity and overtime activity lately” to make up for his reduced earnings after the car accident and shooting. Tr. p. 93. His child-support-obligation worksheet listed his weekly gross income at $3,102, and he provided his W-2s from IMPD for 2022 to 2024 and from Lawrence Township for 2023 and 2024. Father testified that his regular weekly gross income from IMPD based on his salary was $1,732, but with overtime, his average weekly gross income for 2022 to 2024 was $1,901. He explained that his worksheet included a weekly gross income of $3,102 to encompass his base pay and overtime from IMPD as well as his part-time work for Lawrence Township. Father's worksheet imputed a weekly gross income of $1,200 to Mother based on her prior salary at Progressive because she'd voluntarily quit.
[10] Father also testified that he'd paid off the $2,142 child-support arrearage, but the weekly amount of $22 was still being withheld from his income. He estimated that he'd overpaid $4,746.42 in support and asked for a credit for this amount. Father explained that the arrearage was paid off in 2020, but he didn't realize he'd been overpaying until “this year” because “the[ ] funds are automatically deducted from [his] paycheck.” Id. at 120, 121. He acknowledged that he'd made “about four and a half years of payments without requesting any change” to his income-withholding order but said, “[O]nce I realized the amount that I was paying over, ․ that's what I requested.” Id.
[11] The trial court issued an order later in September. It granted Mother's request for Father to exercise parenting time consistent with the Indiana Parenting Time Guidelines, thereby modifying Father's parenting time to one weeknight, every other weekend, and holidays, with extended time in the summer. The court adopted Mother's child-support-obligation worksheet, ordering Father to pay Mother $548 a week in support. The court also granted Father's request for credit for his overpayment of child support. Father filed a motion to correct error as to parenting time and the new support obligation, which the trial court denied.
[12] Father now appeals.
Discussion and Decision
[13] Father appeals the trial court's order modifying his parenting time and child-support obligation. In its order, the trial court entered findings of fact and conclusions thereon. Under Indiana Trial Rule 52(A), we do not set aside the findings or judgment unless they are clearly erroneous. Where, as here, the court enters findings and conclusions sua sponte, we “review[ ] issues covered by the findings with a two-tiered standard of review that asks whether the evidence supports the findings, and whether the findings support the judgment.” Steele-Giri v. Steele, 51 N.E.3d 119, 123 (Ind. 2016). We review any issue not covered by the findings under the general-judgment standard, meaning we may affirm based on any legal theory supported by the evidence. Id. at 124.
I. The trial court did not err in modifying parenting time
[14] Father first argues that the trial court erred in modifying his parenting time. Indiana Code section 31-17-4-2 provides, “The court may modify an order granting or denying parenting time rights whenever modification would serve the best interests of the child.” Parenting-time decisions are reviewed for an abuse of discretion. Perkinson v. Perkinson, 989 N.E.2d 758, 761 (Ind. 2013). In conducting our review, we must “give foremost consideration to the best interests of the child.” Id.
[15] Based on Mother's testimony, the trial court found that the parenting-time modification recommended by Mother was in the children's best interests. See Appellant's App. Vol. 2 p. 17. We agree. After Mother and Father divorced in 2019, when the children were 7 and 5 years old, the parenting-time schedule was six days with Mother followed by three days with Father. By the time of the modification hearing, the children were 13 and 11. Mother explained that because Father's parenting time fell on different days each week, the children struggled to maintain a routine or structure. For example, Ca.C. couldn't play soccer in 2025 because he'd missed the tryouts, which had taken place during Father's parenting time. Mother also provided evidence that there'd been confusion about who gets the children on what days. Additionally, Father sometimes had to drop the children off early in the morning before work since his shift starts at 5:30 a.m. At least once, he dropped Ca.C. off at 4:30 a.m. on a school day after Mother and Father had received reports from Ca.C.’s teacher that he'd been falling asleep in class. Mother ultimately opined that modifying Father's parenting time to the guideline schedule would be best for the children because it would allow them to be more consistent in their extracurricular activities and develop their social lives. Mother's testimony and accompanying exhibits were sufficient to establish that modification of Father's parenting time is in the children's best interests.
[16] Father claims that the trial court “unreasonably curtailed” his parenting time by “failing to take his work schedule into account.” Appellant's Br. p. 20. But just because the new parenting-time arrangement doesn't correspond with Father's work schedule doesn't mean that the trial court didn't take his schedule into account; rather, the court determined that basing parenting time on Father's work schedule was no longer in the children's best interests. The court found that the original parenting-time arrangement, which matched Father's work schedule, “is becoming too chaotic for the minor children and is not providing any stability to the children” because “their days with their father are never the same days of the week and are always on rotation.” Appellant's App. Vol. 2 pp. 14, 15. And in granting Mother's modification request, the court noted, “As the children grow up and continue to participate in extra curricular activities, having a set and reliable schedule becomes more significant.” Id. at 20.
[17] We recognize that because the new parenting-time arrangement doesn't coincide with Father's work schedule, Father will sometimes have the children on days he works. But given the evidence Mother presented, the trial court was within its discretion to find that parenting time consistent with the Guidelines is in the children's best interests. And as the court pointed out in its order, because Father's shifts end at 1:30 p.m., he will still have time to spend with the children even if he is working on the weekends he has parenting time. The trial court did not err in modifying Father's parenting time.
II. The trial court erred in calculating Father's modified child-support obligation
[18] Father next contends that the trial court made multiple errors in modifying his child-support obligation. A trial court's calculation of child support is presumptively valid, and we will set aside the modification of a support obligation only if it is clearly erroneous. Bogner v. Bogner, 29 N.E.3d 733, 738 (Ind. 2015). In reviewing a modification order, we consider only the evidence and reasonable inferences favorable to the judgment. Id.
A. Father's Income
[19] Father claims that the trial court erred in determining his weekly gross income. Where, as here, parents submit separate child-support-obligation worksheets to the court, “[e]ach party bears the burden of justifying the incomes used in his or her own worksheet.” In re Paternity of G.R.G., 829 N.E.2d 114, 119 (Ind. Ct. App. 2005).
[20] Mother moved to modify Father's child-support obligation to encompass his overtime for IMPD and additional part-time jobs. The Indiana Child Support Guidelines recognize that “[t]here are numerous forms of income that are irregular or nonguaranteed,” including overtime and voluntary extra work, “which cause difficulty in accurately determining the gross income of a party.” Ind. Child Support Guideline 3(A), cmt. (2)(b). These forms of irregular or nonguaranteed income may be included in determining a parent's support obligation, but each form is “very fact sensitive.” Id. “Care should be taken to set support based on dependable income, while at the same time providing children with the support to which they are entitled.” Id.
[21] Here, the trial court adopted Mother's worksheet, which included a weekly gross income of $4,651.81 for Father. See Ex. 10. As Father points out, the court didn't enter any findings explaining how it determined his income. Looking to the record, we find no evidence to support the use of $4,651.81 as Father's weekly gross income. Mother testified that she “believe[d]” this number was “based on [20]24 and [20]25,” and she submitted evidence of one of Father's IMPD pay stubs from 2025 and his tax documents from 2024. But Mother didn't explain how the amounts from these exhibits led to a weekly gross income of $4,651.81 or otherwise break down her calculation of Father's weekly income. Additionally, the trial court found that “Father has three current employments and is actively receiving a paycheck from these employers,” Appellant's App. Vol. 2 p. 18, but this finding is not supported by the evidence. Although Father worked for IMPD, Lawrence Township, and a security company in 2024, he gave no indication at the hearing that he was still working at the security company or that his work there continued into 2025. Father's evidence of his 2025 income included only earnings from IMPD and Lawrence Township, not the security company, and the only evidence Mother presented of Father's 2025 income was a pay stub from IMPD. And Mother provides no clarification for her worksheet on appeal—though she argues that the trial court properly included Father's overtime and part-time jobs in calculating his income, she still doesn't explain how she reached $4,651.81. Mother failed to justify the use of this amount as Father's weekly gross income.
[22] Further, although the Child Support Guidelines provide for the inclusion of overtime and voluntary extra work in determining a parent's obligation, “it is not the intent of the Guidelines to require a party who has worked sixty (60) hour weeks to continue doing so indefinitely just to meet a support obligation that is based on that higher level of earnings.” Child Supp. G. 3(A), cmt. (2)(b). A weekly gross income of $4,651.81 is nearly three times Father's weekly base pay from IMPD ($1,732). In 2024, Father earned a total of $149,114 from IMPD, Lawrence Township, and the security company, which appears to be the most he'd ever made in one year. But a weekly income of $4,651.81 comes out to an annual income of $241,894.12. Assigning a weekly gross income to Father that is nearly three times his base pay and based on an annual income that is almost $100,000 more than he's ever earned in a year—especially given that Father's increase in work was situational, as explained further below—is contrary to the intent of the Guidelines. The trial court clearly erred in determining Father's income.
[23] Father doesn't argue that the trial court shouldn't have included his overtime and part-time work in calculating his income; rather, he claims that because his overtime and part-time earnings have varied greatly over the last few years, instead of basing his income on a recent total of these earnings, it should be based on an average of “what he historically earned.” Appellant's Br. p. 23. Based on the facts here, we agree. After suffering work-related injuries in 2023 and 2024, Father was without work or “on a light duty status” for a total of about 15 months. Father explained that he'd “accelerated [his] part-time activity and overtime activity lately” to make up for his reduced earnings during that period. He provided his W-2s from IMPD for 2022 to 2024 and from Lawrence Township for 2023 and 2024, which show significant increases in income in 2024—after he returned to work from his accidents. See Exs. H-I. But as Father explains, these increases don't “represent the historical norm, nor the future.” Appellant's Br. p. 23. Rather, Father picked up additional work after his 15 months of reduced earnings so he could save for a new car and house and pay off debts incurred during that period.
[24] Father's child-support-obligation worksheet listed his weekly gross income as $3,102, which encompassed his earnings from both IMPD and Lawrence Township. He explained that the amount he used for his IMPD income was based on an average of his base pay and overtime from 2022 to 2024. Given that the increases in Father's overtime and part-time work in 2024 were situational and not intended to be his new norm, calculating his weekly gross income based on an average of his earnings before and after the increases is appropriate. See Paternity of G.R.G., 829 N.E.2d at 119 (affirming trial court's use of income averaging to determine father's support obligation where father's income was subject to fluctuation due to varying overtime hours). Such calculation will ensure that Father's support obligation is based on actual, dependable income in accordance with the Guidelines. We therefore remand for the trial court to recalculate Father's obligation based on a weekly gross income of $3,102.
B. Mother's Income
[25] Father argues that Mother is voluntarily underemployed and thus the trial court erred in declining to calculate child support based on her potential income. We will reverse a trial court's decision regarding a parent's unemployment or underemployment and imputation only for an abuse of discretion. In re Paternity of A.B., 267 N.E.3d 510, 519 (Ind. Ct. App. 2025). “The parent arguing for the imputation of income to another parent bears the burden of persuasion.” Walters v. Walters, 186 N.E.3d 1186, 1193 (Ind. Ct. App. 2022).
[26] Indiana Child Support Guideline 3(A)(3) provides, “If a court finds a parent is voluntarily unemployed or underemployed without just cause, child support shall be calculated based on a determination of potential income.” In determining potential income, the court shall determine the parent's employment potential and probable earnings level “based on the [parent's] employment and earnings history, occupational qualifications, educational attainment, literacy, age, health, criminal record or other employment barriers, prevailing job opportunities, and earnings levels in the community.” Id. “Obviously, a great deal of discretion will have to be used in this determination.” Child Supp. G. 3(A), cmt. (2)(c). The Guidelines do not require parents to make career decisions based strictly upon the size of potential paychecks or to work to their full economic potential. In re Paternity of Pickett, 44 N.E.3d 756, 766 (Ind. Ct. App. 2015). Indeed, “legitimate reasons may exist for a parent to leave one position and take a lower paying position,” and “this is a matter entrusted to the trial court.” Id. “It is not our function to approve or disapprove of the lifestyle of parents or their career choices and the means by which they choose to discharge their obligations in general.” Barber v. Henry, 55 N.E.3d 844, 851 (Ind. Ct. App. 2016) (quotation omitted).
[27] Father contends that the trial court should have imputed an income of $50,000 to Mother based on her past salary at Progressive. When the parties divorced in 2019, Mother was selling real estate and had a weekly gross income of $742, see Appellee's App. Vol. 2 p. 16, which amounts to an annual income of $38,584 ($742 x 52 weeks). Mother worked in real estate on and off from 2018 to 2023, and while her annual income varied, she testified that the most she made in a year from real-estate commissions was $40,000. In 2022, Mother got a job at Progressive Insurance with an annual salary of $50,000, but she only worked there for eight months. By the time of the modification hearing, Mother was working only part time, making around $290 a week doing hair at her home salon and teaching yoga classes.
[28] Despite the fluctuations in Mother's income in the years since the divorce, Father would simply have us impute the salary from Mother's highest paying job, even though she only worked there for eight months. And although Father sought to have Mother's potential income based on her $50,000 salary from Progressive, his child-support-obligation worksheet listed a weekly gross income of $1,200 for Mother. This amount is based on earnings of $30 an hour, but Mother's hourly rate at Progressive was $24.44. See Ex. A. Father's counsel asked Mother whether she'd be making at least $30 an hour if she still worked at Progressive, and she responded, “No, that's not how it works,” and said she “can't guarantee” that if she “had stayed, [she] would've gotten a raise.” Tr. p. 56. Additionally, as Mother points out, although the trial court had evidence of her employment and earnings history, Father presented no evidence of any of the other factors in Guideline 3(A)(3) such as her education level, prevailing job opportunities, or earnings levels in the community. See A.B., 267 N.E.3d at 520 (“[A]lthough Mother had the burden to present evidence on her claim that income should be imputed to Father, ․ Mother did not do so. She simply asserted Father's income should be set at what he had previously earned.”). Given the lack of support for the amount imputed to Mother on Father's worksheet and the absence of evidence on many of the enumerated factors for determining potential income, Father failed to meet his burden.
[29] Father additionally claims that the trial court should have imputed potential income to Mother “because her subsequent spouse was able to pay for the financial needs of the family.” Appellant's Br. p. 26. It is true that “[t]he marriage of a parent to a spouse with sufficient affluence to obviate the necessity for the parent to work may give rise to a situation where ․ potential income ․ should be considered in arriving at gross income.” Child Supp. G. 3(A), cmt. (2)(d). “One purpose of potential income is to ․ fairly allocate the support obligation when one parent remarries and, because of the income of the new spouse, chooses not to be employed.” Id., cmt. (2)(c). But Mother didn't choose to be unemployed or underemployed because of her new husband's income. Mother and her husband had their first child together in 2020 (there is no evidence of when they married), but Mother didn't stop working then; she did so in 2023 after having their second child. She explained that she quit Progressive for several reasons—“daycare was too expensive,” and she “did not get off until after 6:00 PM so it didn't give [her] time to help [Ch.C. and Ca.C.] with homework or get them to swim lessons.” Tr. p. 66. And Mother testified that her husband “picked up a better job making more income” when she quit Progressive, not that she'd quit because her husband secured a better job. See Barber, 55 N.E.3d at 852 (“Although [Mother's husband] is in an enviable affluent position to give Mother and the children a more comfortable life, this is not Mother's main reason for not working.”); Carmichael v. Siegel, 754 N.E.2d 619, 626 (Ind. Ct. App. 2001) (“There is no suggestion that Mother has chosen her current job and/or lowered her earnings because of her new spouse's income.”).
[30] Father also points us to the commentary on in-kind benefits, which provides:
[R]egular and continuing payments made by a family member, subsequent spouse, roommate or live-in friend that reduce the parent's costs for housing, utilities, or groceries, may be included as gross income. If there were specific living expenses being paid by a parent which are now being regularly and continually paid by that parent's current spouse or a third party, the value of those assumed expenses may be considered to be in-kind benefits and included as part of the parent's weekly gross income.
Child Supp. G. 3(A), cmt. (2)(d). Father highlights that Mother's husband “pay[s] for the financial needs of the family,” but he presented no evidence as to what those needs are or what specific expenses the husband pays. Without any evidence of the value of Mother's husband's payments, there was no basis for the trial court to impute income to Mother due to expenses being covered. Given the holes in Father's evidence and the lack of facts suggesting that Mother simply chose not to work because of her husband's income, we cannot say the trial court abused its discretion in declining to find that Mother was voluntarily underemployed without just cause. See Thompson v. Thompson, 811 N.E.2d 888, 925 n.35 (Ind. Ct. App. 2004) (where reduction in mother's income was due to “legitimate need to decrease her workload to carry out her increased parental responsibilities,” concluding that “the reduction of income as a result of a legitimate parental responsibility does not constitute voluntary underemployment”), reh'g denied, trans. denied; Carmichael, 754 N.E.2d at 626 (“[B]ecause child support orders cannot be used to force persons to work to their full economic potential, there is no basis in the record for a finding that Mother is underemployed, even if she could theoretically earn more than she currently is earning.”). The court therefore did not err in not imputing additional income to Mother for purposes of calculating child support.
III. The trial court committed prima facie error in crediting Father for his overpayment of child support
[31] In her appellee's brief, Mother argues that the trial court erred in crediting Father for overpayment of child support. See Ind. Appellate Rule 9(D) (“An appellee may cross-appeal without filing a Notice of Appeal by raising cross-appeal issues in the appellee's brief.”). Father didn't file a reply brief and therefore hasn't responded to this claim. “Where an appellant fails to file a response to a cross-appeal, the cross-appellant may prevail if its brief presents a prima facie case of error.” Carter-McMahon v. McMahon, 815 N.E.2d 170, 179 (Ind. Ct. App. 2004). “Prima facie error is error at first sight, on first appearance, or on the face of it.” Id. (quotation omitted).
[32] The well-established rule in Indiana is that overpayments of child support are generally viewed as voluntary and gratuitous, meaning no credit is granted for overpayment. Eisenhut v. Eisenhut, 994 N.E.2d 274, 276 (Ind. Ct. App. 2013); Carpenter v. Carpenter, 891 N.E.2d 587, 600-01 (Ind. Ct. App. 2008). “However, this rule does not fully apply where a parent did not voluntarily build up a substantial credit.” Carpenter, 891 N.E.2d at 601 (quotation omitted). “Therefore, where an overpayment is not voluntary, the amount may be credited to future child support payments.” Id.
[33] Although the trial court here made no finding as to whether Father's overpayment was voluntary, it found, “At no time after paying off his arrears did Father attempt to modify his Income Withholding Order (IWO). Father believes that his arrearage was paid off in 2020, however, 5 years have gone without making any request to amend the IWO garnished from his pay.” Appellant's App. Vol. 2 p. 18. Yet, without further explanation, the court granted Father's request for credit. Mother argues that the court's findings don't support a credit for overpayment and that Father isn't entitled to credit because his overpayment was voluntary. We agree. Although Father testified that he didn't learn until 2025 that he'd overpaid support, he also acknowledged that his arrearage had been paid off in 2020 and gave no explanation for why it took him five years to realize he was overpaying. And though the arrearage amount was automatically deducted from Father's paychecks, Father also admitted that over those five years, he made no effort to amend the income-withholding order. Instead of moving the trial court to terminate the withholding order as soon as he realized the arrearage had been satisfied, Father waited to raise the issue until the modification hearing. See Eisenhut, 994 N.E.2d at 277 (finding voluntary overpayment where there was “a failure on the part of [the father] to take any action to terminate his support obligation for over a year”). Given these facts, Mother has made a showing of prima facie error. We therefore reverse the trial court's credit to Father for overpayment of support.
[34] Affirmed in part, reversed in part, and remanded.
FOOTNOTES
1. Mother also sought modification of legal custody, which the trial court denied, but Mother does not challenge this denial on appeal.
Vaidik, Judge.
Bailey, J., and Scheele, J., concur.
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Docket No: Court of Appeals Case No. 25A-DC-2840
Decided: April 08, 2026
Court: Court of Appeals of Indiana.
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