State of Missouri Department of Social Services, Family Support Division Missouri Cases

Keith Henderson appealed the circuit court's judgment modifying his child support obligation, which had approved an administrative order increasing his payments. Henderson argued the administrative order failed to comply with statutory requirements regarding the continuation of support for an adult child attending college. The appellate court reversed the judgment, finding that the administrative hearing officer failed to make specific findings of fact and conclusions of law regarding the oldest child's emancipation, which was an issue clearly raised by Father. The case was remanded to the circuit court with directions to further remand to the Family Support Division for proper findings or additional evidence.

Michael Shipley appealed the dismissal of his petition to enforce two Eighth Circuit Court of Appeals procedural orders as foreign judgments in Jackson County Circuit Court. Shipley had previously attempted to enforce these orders, which stemmed from a federal § 1983 action against the Family Support Division regarding child support collection. The appellate court affirmed the circuit court's dismissal, holding that the Eighth Circuit's procedural orders were not enforceable judgments. The court also found the appeal frivolous and remanded for the circuit court to determine the costs and fees to be paid by Shipley to the Family Support Division.