New Indiana Case: Swadner v. Swadner Part IV (Work Related Child Care Costs)

Today's issue from Swadner v. Swadner (PDF format) is not as groundbreaking as in Swadner v. Swadner Part I (Children's Names) or Swadner v. Swadner Part III (Relocation). I admit work related child care costs might not have the general interest of Swadner v. Swadner Part II (Joint Custody), but I think it is still important to note this part of the opinion.

Consider this part of the opinion as a good explanation for why we must submit not just child support worksheets but complete worksheets (from page 12 of the opinion):

Because Mother failed to include the work related child care expense on her worksheet, she has waived this issue for review. See Butterfield v. Constantine, 864 N.E.2d 414, 417 (Ind. Ct. App. 2007) (Husband‟s failure to produce a worksheet or any evidence, his failure to object to Mother‟s lack of a worksheet, and his tacit agreement to proceed without a verified worksheet constituted a waiver of his right to appeal the trial court‟s order.) Waiver notwithstanding, we conclude that the trial court acted within its discretion when it apportioned the child care expenses between the parties in the manner discussed above.

Mother's only recourse is to wait for the time to file a modification of child support.