In Dunn v. Jones,[1] the supreme court held it was not an abuse of discretion to calculate a parent’s annual income based on a single paystub in order to determine child support. Nicholas Ryan Dunn filed a motion to modify child support because his income had decreased. The trial court calculated his income based on the second highest of the four paystubs he submitted to the court. On appeal, Dunn argued that the trial court abused its discretion by using only one paystub to calculate his annual income rather than averaging all of the paystubs together. The supreme court affirmed the lower court’s calculation, reasoning that child support amounts are meant to accurately reflect a parent’s economic reality. The trial court could have reasonably determined that the lesser paystubs, the first Dunn received from a new job, were not accurate indicators of his economic reality. Affirming the lower court’s decision, the supreme court held that it was not an abuse of discretion to calculate an annual income based on one paystub for child support purposes.
[1] 451 P.3d 375 (Alaska 2019).
