Garwood v. Wyatt: Child Support Under Fire — How Calculations and Arrearages Can Drive Appeal

Child support cases can get very complicated very fast, especially when a parent’s income changes or someone claims the other side isn’t holding up their end of the bargain. In Florida, such disputes end up being appealed, and a big reason is simple math errors or confusion over how past-due payments are calculated. For example, the case of Garwood v. Wyatt. This is a 2025 case where the former husband pushed back against a modified support order and an updated arrearage total. In this case, the appellate court ended up reversing part of the trial court’s decision, mostly because of technical mistakes. It’s a good example of how even small missteps in the numbers can lead to bigger legal consequences, especially when timesharing or finances are in flux.

Background of the case

The parties, married in 2012 and divorced in 2015, had two children. Under the original final judgment, the former husband was ordered to pay monthly child support.

In 2017, the former wife (now appellee) filed a supplemental petition under allegations that the husband was not exercising his timesharing responsibilities. After a 2018 trial, the court entered a supplemental final judgment increasing the husband’s support obligation.

By January 2020, the wife moved to enforce the supplemental support order. The court found the husband willfully violated the order and held him in contempt, establishing arrears as of May 2020 and imposed a repayment schedule.

In June 2020, the husband responded with a supplemental petition seeking modification. He claimed lower net income and sought increased timesharing, arguing his support obligation should be reduced accordingly.

After a trial in 2022, the court entered a detailed second final judgment. That order recalculated the husband’s child support obligation retroactively and assessed total child support arrears since the original divorce, covering multiple time periods during which the parties’ incomes changed.

The appeal

On appeal, the husband argued that the trial court miscalculated his support obligations and arrears. The appellate court couldn’t fully review the factual findings because of a missing trial transcript, but it did spot errors just by looking at the judgment itself. In the earlier periods, the trial court incorrectly subtracted his minimum obligation from the wife’s and treated the difference as his monthly support, even when her income was higher. For later periods, the math was mostly sound, but the totals were off due to incorrect multiplication. The court also found that arrears were miscalculated because the trial court relied on outdated figures. Since there were clear math records, the appellate court reversed the decision and sent it back to the trial court for correction.

Talk to a Tampa, FL, Child Support Lawyer Today

Westchase Law, P.A., represents the interests of parents during child custody and support hearings. Call our Tampa family lawyers today to schedule an appointment, and we can begin discussing your next steps right away.

Source:

caselaw.findlaw.com/court/dis-crt-app-flo-six-dis/117201152.html