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Shelhammer v. Hodges

Shelhammer v. Hodges, 2016 MT 29 (Feb. 9, 2016) (Shea, J.) (5-0, aff’d)

Issue: Whether a parent’s military housing and subsistence allowances are part of the parent’s actual income when calculating child support obligations.

Short Answer: Yes.


Facts: Shelhammer and Hodges are the parents of AS. CSED ordered Shelhammer to pay Hodges $74/month child support in October 1999. In May 2014, Hodges filed a request for review, and CSED modified Shelhammer’s obligation to $743/month.…

In re the Adoption of PTH

In re the Adoption of PTH, 2015 MT 316 (Nov. 10, 2015) (McGrath, C.J.) (5-0, aff’d)

Issue: (1) Whether the district court erred by giving full faith and credit to the parenting plan and child support order entered by the California court; and (2) whether the district court erred by refusing to terminate Father’s parental rights.

Short Answer: (1) No; and (2) no.


Facts: PTH was born in 2008 to TC, Mother, and RH, Father. The parents divorced and agreed to a parenting plan approved by the county court in California, where they lived. According to the parenting plan, RH was not required to pay any child support. Neither parent has moved to modify the parenting plan or child support provision.…