Katzman v. Healy

933 N.E.2d 156 (2010)

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Katzman v. Healy

Massachusetts Appeals Court
933 N.E.2d 156 (2010)

Facts

Anna Katzman (plaintiff) and Timothy Healy (defendant) married and had two children. Katzman and Healy later separated and entered into a divorce agreement, and their marriage was dissolved in 2006. The divorce agreement was incorporated into the court’s order of divorce and contained the terms of Katzman and Healy’s parenting time and child support. Healy and Katzman agreed that Healy’s child-support obligation would be calculated on his base weekly salary, and if he received a cash bonus, he would pay Katzman 20 percent of the net bonus amount. Katzman and Healy agreed that Healy’s child-support obligation would be about $3,000 per month and included a procedure for a child-support modification. At that time, Healy was earning $150,000 per year as the chief executive officer of a corporation and Katzman was earning $42,000 as a registered nurse. Katzman and Healy equitably divided about 600,000 shares of stock in the corporation, which had not yet gone public and therefore had a current value of $0. By March 2007, Healy’s salary had risen to $325,000. Katzman had voluntarily resigned from her position as a registered nurse and sought an increase in child support. In May 2007, the corporation had its initial public offering and closed at about $30 per share. Afterwards, the trial court ordered an increase in Healy’s child-support obligation, finding that the net worth of Katzman and Healy had greatly increased since the divorce and that Katzman would not be able to provide the same lifestyle for the children that Healy could. Pursuant to the child-support guidelines, the trial court calculated the minimum presumptive amount at about $2,760 per month, which was based on the amount of child support Healy would have been ordered to pay if he earned $250,000. The court then added 15 percent of the increase in Healy’s base weekly salary realized since the divorce, meaning that Healy’s child-support obligation was about $6,000 per month. Healy appealed, arguing that the trial court did not properly calculate his child-support obligation.

Rule of Law

Issue

Holding and Reasoning (Kafker, J.)

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