Million v. Million

1 Citing case

  1. Begnaud v. Begnaud

    No. 2023-CA-00822-COA (Miss. Ct. App. Jan. 7, 2025)

    Courts in other states have reached similar conclusions regarding adoption assistance payments and have held that such payments should not be credited against an obligation to pay child support. See Tluzek v. Tluzek, 179 So.3d 455, 456 (Fla. 5th Dist. Ct. App. 2015) (a child support payor is not entitled to a credit against his child support obligation based on adoption assistance payments paid by the state); Hamblen, 54 P.3d at 374 (¶13) (adoption assistance payments are not "the parents' property" but rather are paid for the benefit of "the children to address their special needs"); Million v. Million, No. 28651, 2020 WL 5989214 4 (¶13) (Ohio Ct. App. 2020) ("Adoption Assistance stipends should be treated as analogous to [Social Security] benefits received by a disabled child because the adoption stipends are for the benefit of the child, and not the parent, as the subsidy is based upon the child's special needs."); see also, e.g., In re Hennessey-Martin, 855 A.2d 409, 411-13 (2004) (holding that a child support payor was not entitled to a credit against his child support obligation for adoption assistance payments); Gambill v. Gambill, 137 P.3d 685, 689-90 (Okla.Civ.App. 2006) (same); W.R. v. C.R., 75 So.3d 159, 169 (Ala. Civ. App. 2011) (same); Burcham v. Burcham, 886 N.W.2d 536, 551 (Neb. Ct. App. 2016) (same). CONCLUSION