A Florida appellate court has overturned part of an Okeechobee County divorce decree after a trial judge used an unsupported six-figure income to set child support without explaining where the number came from.
Background
In an opinion issued July 29, 2026, the Fourth District Court of Appeal reversed the child support decision in the case of Jennifer C. Mathis v. Charles Jason Mathis, sending the matter back to the circuit court to properly establish income and recalculate support.
During the trial in the Nineteenth Judicial Circuit, Jennifer Mathis testified that she worked about 20 hours per week as an employee making $55 per hour, bringing in between $2,200 and $2,500 biweekly—or roughly $57,200 annually. Her updated financial affidavit listed a gross monthly income of $4,960.83, which comes out to roughly $59,530 per year.
Despite that evidence, Circuit Judge Leatha Dawn Mullins entered a supplemental final judgment using an annual gross income figure of $111,516 for Jennifer Mathis to calculate child support. Based on that figure, the trial court ordered that neither parent pay child support.
Appeals Court Ruling
Writing for the appellate court, Judge Shaw pointed out that the trial judge gave no rationale or evidentiary backing for the much higher income amount. Under Florida law, courts can impute income—assigning higher earnings if a parent is voluntarily underemployed—only if specific factual findings are placed on the record.
However, Judge Mullins had explicitly stated in her judgment that she was not imputing income to either party. “Because the supplemental final judgment does not identify the evidentiary basis for the wife’s income, meaningful appellate review is impossible, and the resulting child support award is unsupported by competent, substantial evidence,” Judge Shaw wrote.
Original reporting: Tampa Free Press — read the source article.