Missouri Court of Appeals, Western District / Aug 27, 2019
John F. Warkenthien vs. Family Support Division, Department of Social Services, State of Missouri
John F. Warkenthien appealed an administrative determination by the Family Support Division (FSD) that he owed over $2,500 in child support arrearages, leading to the denial of his passport renewal. Father argued that college expenses and spousal maintenance should not be considered child support for certification purposes. The appellate court affirmed the FSD's determination, holding that court-ordered post-secondary educational expenses constitute child support under both federal and Missouri law, thereby exceeding the statutory threshold for passport denial.