In re Schneider

Carol Schneider (plaintiff) and Jeffrey Almgren (defendant) had two children, Amanda and D.J.A. Schneider and Almgren divorced in 1997 in Nebraska, and the dissolution decree ordered Almgren to pay child support during the children’s minority. In Nebraska, the age of majority was 19, and child support did not extend past the age of minority unless the parties agreed otherwise. Schneider, Amanda, and D.J.A. moved to Washington state. In 2009, when Amanda was 18 and preparing to enroll in college, Schneider moved the Washington court to upwardly modify the Nebraska child-support order to provide support for Amanda’s postsecondary education. Almgren moved the Washington court for a downward modification in his support of D.J.A., because Almgren had lost his job. When Almgren filed his motion, he submitted to personal jurisdiction in Washington and established Washington’s jurisdiction to modify the Nebraska order under the Uniform Interstate Family Support Act (UIFSA). The trial court granted Schneider’s motion, extending Almgren’s child support until Amanda reached the age of 23, the upper age limit of postsecondary-education support in Washington. The trial court denied Almgren’s motion. Almgren appealed, arguing that the Washington court did not have the authority under the UIFSA to extend support past the age of majority in Nebraska. The appellate court affirmed the trial court’s ruling, and Almgren appealed again.