Appeals Court Hears Challenge to Modified Support Order That Increased Father’s Obligations
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Summary
Paul Steinberg appealed a modification that converted variable child support, alimony and college contributions into fixed awards and added a 15% upward deviation; appellant says the judgment exceeds the mother's needs and rewrites the parties’ bargain while appellee argues the record supports the award.
The Appeals Court heard argument in Lisonbee Steinberg v. Paul Steinberg (24P1164), an appeal from a probate and family court modification that increased the father's fixed support obligations.
Juliana Zane, representing the father, told the panel the trial court's judgment "rewrote the parties' bargain" by making previously variable awards fixed and converting the combined obligation to an amount the appellant says represents at least 41% of the father's gross base income. Zane argued the judgment lacked necessary findings about the marital lifestyle and that the upward deviation from child support guidelines lacked support on the record.
Kevin Korr, representing Melissa Steinberg, said Judge Allen carefully credited the parties' financial affidavits and that Kavanaugh step‑two analysis supports the award. Korr described the family's historical high earnings and variable compensation — including stock options and bonuses — and said the judgment was designed to address the mother's resulting shortfall.
The panel focused on whether the judge made required findings for deviating from guidelines, whether the combined order exceeded demonstrated needs, and whether the evidence in the record supports remand for recalculation.
The matter was submitted after argument; the written decision will determine whether the modification should be vacated, affirmed or remanded for further findings.
