The appellant appealed a supplementary family arbitration award concerning child support income calculations and spousal support.
She argued the arbitrator erred by using a formula to determine income rather than strictly applying the Federal Child Support Guidelines, by declining to apply the Spousal Support Advisory Guidelines, and by providing insufficient reasons for the spousal support amount and commencement date.
The court held the arbitrator did not err in maintaining the previously ordered income-calculation formula, noting the appellant had originally requested that approach and did not appeal the earlier award.
The court also found no error in declining to apply the Spousal Support Advisory Guidelines given the parties’ agreement, the high income involved, and the atypical circumstances.
Applying the standard of review for arbitral awards, the court concluded there was no palpable and overriding error and that the reasons were adequate when read together with the earlier award.
