Harmon v. Department of Social and Health Services

951 P.2d 770 (1998)

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Harmon v. Department of Social and Health Services

Washington Supreme Court
951 P.2d 770 (1998)

RW

Facts

Edward Harmon (plaintiff) married the divorced mother of two daughters, thereby becoming the girls’ stepfather. Seven years later, the girls left the Harmons and went to live with their biological father, to whom the family court transferred legal custody. Harmon remained married to the girls’ biological mother, and therefore, an administrative-law judge (ALJ) for the Washington Department of Social and Health Services (department) (defendant) ruled that Harmon had an ongoing obligation to help support the girls financially. The ALJ’s ruling was based in part on the state’s 1881 family-expenses statute, which made both spouses in a marriage equally responsible for supporting their children. That statute had been amended in 1969 to provide that, with respect to stepchildren, the dissolution of a stepparent’s marriage would terminate the stepparent’s legal obligations toward the stepchildren. After an intermediate appellate court affirmed the ALJ’s ruling, Harmon appealed to the Washington Supreme Court, which construed the family-expenses statute in light of the state’s child-support statute, which made the respective incomes of the biological parents the determining factor in calculating child-support payments.

Rule of Law

Issue

Holding and Reasoning (Guy, J.)

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