M.F., Appellant, v. S.B., Respondent. (2026)

Introduction

M.F. (Father) appeals from the trial court's judgment awarding $310 in monthly child support to S.B. (Mother) for minor children A.F. and J.F. Father raises one point on appeal arguing: the trial court erred in calculating the presumed correct support amount (PCSA) by (1) failing to apply the required split-custody Form 14 methodology and (2) by incorrectly designating Father as the Parent Paying Support for A.F. Because Father failed to preserve this issue for appellate review and did not request plain error review, we affirm.

Factual and Procedural Background

Father sought a declaration of paternity, custody, and support on February 15, 2023 regarding M.I.F. (emancipated by the time of trial), J.F., and A.F. Following a bench trial, the trial court confirmed Father's paternity for all three children.

The trial court awarded Mother and Father joint physical custody of J.F. and A.F. J.F. was to reside primarily with Mother, with Father having custody every other weekend; A.F. would switch residences weekly between each parent. Neither party submitted a Form 14 to the trial court. As to child support, the trial court first found gross monthly incomes of $3583 for Mother and $2912 for Father. The trial court then completed two different Form 14s to calculate the PCSA, one for each child's residential circumstances. However, each form was calculated as if for two children, and with Father designated as the Parent Paying Support on both forms. Finally, the trial court found both forms “unjust and inappropriate” and averaged them, calculating an award of $310 in monthly child support to Mother, retroactive to October 2023. Father filed a timely motion for amended judgment or, in the alternative, a new trial, which the trial court denied. This appeal follows.

Standard of Review

Appellate review of a court-tried case is governed by Murphy v. Carron, 536 S.W.2d 30, 32 (Mo. banc 1976). Mehler v. Martin, 440 S.W.3d 529, 531 (Mo. App. E.D. 2014). The judgment will be affirmed unless it is unsupported by substantial evidence, is against the weight of the evidence, or erroneously declares or applies the law. Nelson v. Nelson, 195 S.W.3d 502, 510 (Mo. App. W.D. 2006). We review questions of law de novo. C.A.W. v. N.K.D., 718 S.W.3d 126, 128 (Mo. App. E.D. 2025).

Analysis

Father alleges the trial court misapplied the law by failing to use the dual-form PCSA calculation method in split-custody cases. Father also alleges the trial court misapplied the law by incorrectly designating him as the Parent Paying Support on the Form 14 for A.F. because there is a rebuttable presumption that Mother, as the higher-earning parent, is the proper Parent Paying Support.¹ Because Father failed to file a Form 14 and therefore did not preserve this issue for review, we affirm.

Section 452.340 ² and Rule 88.01, which govern child support determinations, mandate the use of Form 14 to calculate child support. C.A.W., 718 S.W.3d at 128–29. This is a two-step process. First, the trial court must calculate the PCSA pursuant to Form 14, either by accepting one of the parties’ proposed calculations or by rejecting the parties’ Form 14s and substituting its own. Id. at 129. Next, the court must consider whether to rebut the PCSA as “unjust or inappropriate” after considering all relevant circumstances. Id.

Though the trial court may substitute its own Form 14 for one of the parties’ in determining the PCSA, the record contains no Form 14 filed by either party. Father's failure to file a Form 14 is fatal to his appeal. “A party must have submitted a completed Form 14 in order to preserve for appellate review a claim of error in the determination of child support.” In re Marriage of Bullard, 18 S.W.3d 134, 139 (Mo. App. E.D. 2000) (citing Mills v. Mills, 939 S.W.2d 72, 75 (Mo. App. W.D. 1997)); see also Weber v. Deming, 292 S.W.3d 914, 920 (Mo. App. W.D. 2009) (“One who wishes to complain about a child support calculation must have submitted a Form 14 to the trial court.” (quoting Yun v. Yun, 908 S.W.2d 787, 791 (Mo. App. W.D. 1995))); Ibrahim v. Ibrahim, 825 S.W.2d 391, 398 (Mo. App. S.D. 1992) (“[Challenging child support without having submitted a Form 14] is akin to pursuing a different theory for recovery on appeal than was pursued at trial.”). Because Father has failed to file a Form 14 with the trial court, he has not preserved his claim for review.

Father's point “can only be reviewed, if at all, for plain error.” Int. of K.C.G., 689 S.W.3d 759, 764 (Mo. App. S.D. 2024). Father has not requested plain error review. “This Court will not ‘sua sponte, review for plain error’ when an appellant has not requested that analysis.” Id. (quoting Int. of L.J.H., 604 S.W.3d 883, 889 (Mo. App. W.D. 2020)). Father's point is denied.

Conclusion

For the reasons stated above, we affirm trial court's judgment.

FOOTNOTES

1.   Father's point relied on is multifarious, raising two distinct grounds for reversal, violating Rule 84.04(d). However, this Court may review deficient points ex gratia. Cedar Cnty. Comm'n v. Governor Michael Parson, 661 S.W.3d 766, 772 (Mo. banc 2023). We choose to do so here.

2.   All section references are to RSMo (2016). All rule references are to the Missouri Supreme Court Rules (2025).

Virginia W. Lay, Presiding Judge

Angela T. Quigless, Judge, concurs. Thomas C. Clark, II, Judge, concurs.