Florida court ordered fresh child-support calculation after husband's household payments were counted as wife's income. (AI image)
A Florida appeals court on Wednesday ordered a fresh calculation of child support in a dispute involving a mother whose monthly income of $1,500 had been assessed at $10,100 after a lower court included $8,600 paid by her new husband towards household expenses.According to the judgment document available on Justia, Bianca Rampartap had sought higher child support from her former husband, Darryl Rampartap, who had moved to Trinidad and stopped spending parenting time with their child. After the lower court included the money spent by her new husband as her income, the appeals court has now ruled that it could not be treated as her income simply because he covered those expenses.Rampartap and her former husband, Darryl Rampartap, divorced in 2016.
Nearly a decade later, their disagreement over financial support for their child brought them back to court. By then, Bianca had remarried, while Darryl had moved abroad.The dispute arose after Bianca sought a change in child support because she was caring for their child without any parenting time being exercised by Darryl. Although the court accepted that their circumstances had changed, the calculation of the revised payment created another problem.
The court assessed Bianca's new husband's expenses as part of her finances, even though her own reported earnings were much lower. In her challenge to the decision, Bianca maintained that money spent by her husband on their shared household was not income paid to her.
Parents' financial arrangement changed
When Bianca and Darryl divorced in 2016, they were given equal parenting time. They also had to share the costs of their child's extracurricular activities, uniforms, equipment and summer camp.
Bianca was responsible for 40% of those expenses, while Darryl had to cover the remaining 60%.No child-support payment was ordered initially. In 2018, however, the court directed Darryl to pay $225.42 in child support, described in the judgment as bimonthly. The parents were also asked to divide the costs of extracurricular activities and summer camp equally.The arrangement continued until Bianca approached the court again in 2024.
She said Darryl had left the United States and was no longer spending overnight time with their child, despite the earlier arrangement being based on shared parenting.The court found that Darryl had not exercised his parenting time for eight months. It also accepted testimony that he was permanently living in Trinidad. Bianca was then given full parenting time, sole parental responsibility and authority to make decisions concerning their child.The earlier child-support arrangement thus needed to be reviewed. The court therfore referred the financial question to a hearing officer, who examined the parents' incomes and expenses before recommending a new payment.
Why mother's income was calculated at $10,100
Bianca told the hearing officer that she earned $1,500 a month before deductions. Her financial statement also showed that her current husband was covering household expenses of $8,600 every month.The hearing officer added those expenses to Bianca's earnings, arriving at a monthly income of $10,100. The reasoning was that her husband's payments reduced the amount she needed to spend on maintaining the household.This figure was then used to calculate the parents' respective contributions. Darryl was ordered to pay $403 a month in child support from July 2025. He also owed $1,953.38 in payments dating back to August 2024.Bianca objected to the calculation, arguing that her husband's financial contribution to their home should not be treated in the same way as money she personally earned or received. After the lower court rejected her attempts to challenge the decision, she appealed.
Appeals court disagreed with the lower court
The appeals court focused on the difference between receiving financial help and sharing household expenses with a spouse.Florida law allows certain payments made on someone's behalf to be included when calculating their income.
However, the judges found that Bianca's husband was paying expenses for the home in which he also lived. The payments were not made to Bianca, and there was no sufficient evidence to justify adding the entire $8,600 to her income.The judgment read, “When the new husband merely paid the household expenses for his own household, no ‘payment,’ in kind or otherwise, had been made to his wife.”The court explained that financial assistance from relatives or other people could still qualify as income in some situations.
What mattered was whether the money was actually being provided to the parent, rather than simply being spent on a shared home.
What happens to the child-support payments now?
The appeals court also noticed an inconsistency in the earlier financial figures. Bianca's income had been recorded as $10,100 before deductions and $10,487 after deductions. The judges believed the two figures had been mistakenly switched.Using those figures, the earlier calculation had assigned Bianca 80.43% of the parents' combined income and Darryl 19.57%. Those percentages helped determine the amount Darryl was required to pay.The appeals court has now directed the lower court to determine Bianca's income again and recalculate the child-support obligations.