Y.R.

—Appellant Y.R., mother of Z., appeals the trial court’s order awarding child support from respondent A.F., father of Z., in an amount that deviated downward from the statewide uniform guideline by a substantial amount. Appellant contends the court failed to state its reasons for awarding less than the guideline or for concluding the amount awarded was in Z.’s best interests, as required by Family Code section 4056, subdivision (a). 1 She further contends the court erroneously based the award on appellant’s and Z.’s historical expenses rather than the disposable income and lifestyle of respondent—an extraordinarily high-income earner—and placed on appellant the burden of proving the guideline amount reasonable, rather than requiring respondent to prove the guideline amount unjust or inappropriate. Finally, appellant contends respondent presented insufficient evidence to support a deviation from the guideline.

We conclude that the trial court’s failure to comply with the requirements of section 4056, subdivision (a) mandates reversal, despite the existence of evidence sufficient to warrant a deviation from the guideline. We further conclude that the court’s reliance on…