Style v. Shaub

Sharon Style (plaintiff) and Ronald Shaub (defendant) had one child, Dustin (plaintiff). Ronald paid child support, and Sharon had custody. When Dustin turned 18, the Lancaster County Domestic Relations Office (DRO) sent Sharon notice that Dustin’s child support would be terminated unless she notified the DRO within 30 days with a reason for ongoing support. Sharon did not respond to the DRO, and child support was terminated. Approximately three months later, Sharon filed for child support on Dustin’s behalf, arguing that the then 19-year-old Dustin had psychiatric and medical disabilities that precluded him from obtaining self-supporting employment. At a hearing, it was determined that Dustin had suffered from disabilities for most of his life. Dustin’s employment history showed mixed performance at three jobs. At the time of trial, Dustin was enrolled in vocational training for persons with disabilities at the Hiram G. Andrews Center. Dr. Hogarth, Dustin’s vocational evaluator, testified that Dustin needed rehabilitative services but he was guardedly optimistic Dustin could successfully enter the workforce if the job accommodated his needs for a minimally distracting environment and repetitive tasks. There was no specific evidence presented about what jobs Dustin could perform, what compensation he could reasonably receive, and whether that income would allow him to be self-supporting. The trial court dismissed Sharon’s complaint, finding that her failure to respond to the DRO equitably estopped her from seeking child support and that there was insufficient evidence to rebut the presumption that Dustin was no longer entitled to child support after reaching his majority. Sharon appealed.