Custody; Children’s best-interests factors (c), (d), (h) & (k); Child support

The court affirmed the trial court’s custody decision and remanded for further analysis as to the issue of child support. In Docket No. 357875, defendant-father appealed the trial court’s 6/29/21 opinion and order, where the trial court estimated his income for purposes of child support. In Docket No. 358428, he appealed the trial court’s 9/1/21 order, which granted plaintiff-mother “sole custody of the parties’ children and ordered defendant to pay $1,896 each month in child support.” As to custody, the court held that in light of its “conclusions that the trial court’s findings on factors (c), (d), (h) and (k) were not clearly erroneous,” there was no basis for the court to hold that “the trial court abused its discretion by awarding plaintiff sole custody.” This was “especially the case when considering that the trial court did not conclude that any of the factors weighed in favor of defendant.” Although defendant argued that “the trial court failed to give factors (a), (e), (f), and (g) sufficient weight, ‘[a] court need not give equal weight to all the factors, but may consider the relative weight of the factors as appropriate to the circumstances.’” The court held that given “the parties were unable to cooperate and agree generally concerning important decisions affecting the welfare of their children, and given the best-interest factors, . . . the trial court did not abuse its discretion by awarding plaintiff sole custody.” Also, as to child support, the court concluded that it was necessary to remand for further consideration.