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Teran v. Rittley

Michigan Court of Appeals

882 N.W.2d 181 (2015)

Facts

Michael Rittley (defendant) was stationed in Quito, Ecuador, where he fathered a child with Susana Teran (plaintiff). Rittley then left the country without providing his contact information to Teran. A few years later, Teran filed a paternity action in the United States to determine custody and child support. A paternity test established that Rittley was the father. The friend of the court (FOC)—the investigative and enforcement arm of the Michigan family-court system—recommended a child-support order of $1,211 per month based on the standard formula. Rittley argued that the amount should be lower because the cost of living is much lower in Ecuador—a disparity established by testimony from an economics expert. The trial court rejected this argument and set child support at the $1,211 monthly amount. Rittley appealed. The Michigan Court of Appeals granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Per curiam)

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