This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case involves a mother and her adult child seeking past child support from the father. The mother and father had a relationship in 1969, resulting in the birth of the child. The father initially denied paternity and provided minimal financial support. The mother did not pursue child support during the child’s minority. In 1990, after the child reached the age of majority, the mother and child filed a complaint to establish paternity and claim past and future child support. The father admitted paternity but contested the claims for past support (paras 3-6).
Procedural History
- District Court, Grant County: The trial court applied a four-year statute of limitations to the claim for past child support, barring recovery for support accrued before March 14, 1986. It awarded the mother over $15,000 for support from March 14, 1986, to February 17, 1987, but denied prejudgment interest and excluded evidence of the father’s wealth (paras 9-11).
Parties' Submissions
- Appellants (Mother and Child): Argued that the trial court erred in applying the general four-year statute of limitations instead of the Uniform Parentage Act’s three-year limitation after the child’s majority. They contended that the trial court’s interpretation violated public policy, unjustly enriched the father, and denied equal protection. They also argued that the court improperly excluded evidence of the father’s wealth and erred in denying prejudgment interest (paras 18-22, 26-27, 33-34, 39-40).
- Respondent (Father): Asserted that the general four-year statute of limitations was correctly applied and that the mother’s and child’s claims were time-barred. He argued that evidence of his wealth was irrelevant since his income was already considered. He also contended that prejudgment interest was unwarranted because the amounts owed were unliquidated and uncertain until determined by the court (paras 19-21, 33-35, 40-41).
Legal Issues
- Whether the trial court erred in applying the general four-year statute of limitations to the claim for past child support.
- Whether the trial court’s interpretation of the paternity statute violated public policy and led to the unjust enrichment of the father.
- Whether the trial court erred in excluding evidence of the father’s wealth in determining past child support.
- Whether the trial court erred in denying prejudgment interest on the past child support award.
Disposition
- The Court of Appeals reversed the trial court’s application of the four-year statute of limitations and held that the Uniform Parentage Act’s three-year limitation after the child’s majority applied (paras 24-25, 32).
- The Court of Appeals reversed the trial court’s exclusion of evidence of the father’s wealth and remanded for reconsideration of the past child support award (paras 37-38).
- The Court of Appeals affirmed the trial court’s denial of prejudgment interest (paras 43-44).
Reasons
Per Alarid J. (Apodaca and Black JJ. concurring):
Statute of Limitations: The court held that the Uniform Parentage Act’s three-year statute of limitations after the child’s majority applied to both paternity and support actions. Applying the general four-year statute of limitations was inconsistent with the Act’s purpose of ensuring support for children and violated equal protection by imposing shorter limitations on illegitimate children (paras 24-25, 30-32).
Public Policy and Unjust Enrichment: The court found that applying a shorter statute of limitations undermined public policy by allowing the father to avoid his support obligations, leading to unjust enrichment. The Act’s broader limitations period better aligned with the state’s policy of ensuring parental support (paras 26-32).
Exclusion of Evidence of Wealth: The court determined that the trial court erred in excluding evidence of the father’s wealth, as it was relevant to determining his ability to pay child support. The trial court’s reliance solely on the father’s income was too restrictive and inconsistent with established guidelines (paras 33-38).
Prejudgment Interest: The court upheld the denial of prejudgment interest, reasoning that the amounts owed were unliquidated and uncertain until determined by the court. The father had no legal obligation to pay support until paternity was established, and thus, no interest could accrue (paras 43-44).
The case was remanded for further proceedings to determine the appropriate amount of past child support, considering the father’s wealth and the correct statute of limitations (para 45).