Marriage of Quezada CA4/3

FACTS

The 1997 California Child Support Order Catherine and Steven divorced in 1993. They had two minor children—a son born in 1990, and a daughter born in 1991. Catherine was granted primary physical custody of the children, and Steven was ordered to pay child support of $983 per month—$369 for his son and $614 for his daughter. Steven and Catherine were each required to maintain the children on “medical insurance as available through their respective places of employment.”

In California, the UIFSA is codified at Family Code section 4900 et seq. Although California has adopted the 2001 version of the UIFSA, it has not yet become effective and, thus, the 1996 version of the UIFSA is the operative version for purposes of this appeal. (In re Marriage of Haugh (2014) 225 Cal.App.4th 963, 968, fn. 2 (Haugh); Knabe v. Brister (2007) 154 Cal.App.4th 1316, 1319, fn. 2.) All further statutory references are to the Family Code, unless otherwise indicated.

2 On July 10, 1997, the Orange County Superior Court, ruling on Steven’s motion to modify child support, entered the relevant child support order in this case (hereafter the 1997 California Child Support Order). The…