Child Support Guidelines – Unconstitutional?

The Minnesota Court of Appeals has turned back a challenge to Minnesota’s child support guidelines. Ruling in the case of Doll v. Barnell, Case No. AO4-925, AO4-1146 (Minn. Ct. Appeals March 22, 2005), the Court of Appeals recited and dismissed the appellants’ various constitutional challenges to Minnesota’s child support guidelines.

The appellants had argued that child support guidelines by their very nature violate the U.S. Constitution’s Supremacy Clause, Equal Protection Clause, and Due Process Clause. The appeals court stated that Minnesota statutes are presumed to be constitutional and should be declared unconstitutional “only with extreme caution and only when absolutely necessary.”

The appeals court first ruled that there was no protected class or fundamental right involved, so the appropriate standard is one of rational basis rather than strict scrutiny. In so doing, the appeals court rejected the appellants’ contention that noncustodial parents had a fundamental right to control the care of their children as well as the contention that the statute disproportionately burdens men.

The appeals court rejected the equal protection challenge, because it rejected the assertion that noncustodial parents were similarly situated to custodial parents.

The appellants had argued that their right to due process was being violated. Their primary argument here was that the child support guidelines sometimes required the payment of more than custodial parents actually need to support the children. Again, the appeals court looked to the “rational basis” test:

As indicated in the legislative history of the guidelines, from the beginning, Minnesota has endeavored to tailor the guidelines to render fair and reasonable child-support amounts, and the cost of rearing has been part of that formula. At best, appellants and R-KIDS’ submissions show that the “adequacy” of awards is subject to debate. But a statute is not rendered unconstitutional simply because it “is not made with mathematical nicety or because in practice it results in some inequality.” Dandridge v. Williams, 397 U.S. 471, 485, 90 S. Ct. 1153, 1161, 25 L. Ed. 2d 491 (1970) (quoting Lindsley v. Natural Carbonic Gas Co., 220 U.S. 61, 78, 31 S. Ct. 337, 340, 55 L. Ed. 369 (1911)).

Finally, the appellants had argued that the child support guidelines violated federal law and thus ran afoul of the Supremacy Clause. They argued that Minnesota had failed to consider economic data on the cost of raising children as required by federal regulations (45 C.F.R. § 302.56(h)). The appeals court cited evidence that Minnesota had indeed considered such economic data and rejected this argument; then it added dictum to the effect that this didn’t matter anyway: “Moreover, even if the evidence established that Minnesota’s review of its guidelines was deficient, conflict with the federal law would not be significant for preemption purposes; the state would simply be ineligible for incentive payments under the federal scheme. There is no federal preemption of state law.”

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