The Maine Supreme Judicial Court reversed a lower court's child support ruling in *Carson Waterman v. Grady Wheeler* (2025 ME 96), holding that a father who shares equal custody of his daughter should receive consideration for a child support adjustment after the birth of a new child.
The case centers on Grady Wheeler's appeal from a District Court judgment ordering him to begin paying child support to Carson Waterman for their 10-year-old daughter. The dispute arose when Wheeler requested an adjustment to his support obligations following the birth of his son during pending modification proceedings.
Waterman and Wheeler are parents to a daughter who is now 10 years old. The former couple initially obtained a parental rights judgment in 2016 that awarded them shared parental rights but required Wheeler to pay child support to Waterman. The arrangement changed significantly in 2020 when the parties agreed to an amended order that reduced Wheeler's child support obligation to zero dollars and established that their daughter "resides equally with both parents."
The legal conflict began in December 2023 when both parties filed opposing motions to modify their arrangement. Waterman sought to reinstate Wheeler's child support payments, while Wheeler opposed the request. During the pendency of these motions, Wheeler's son was born to another woman. The new child is not subject to the court's child support order because Waterman is not the mother.
The District Court, presided over by Judge Janelle in Biddeford, ruled in favor of Waterman's motion and ordered Wheeler to begin paying child support again. However, the court declined Wheeler's request for a downward adjustment to account for his new child. The trial court reasoned that because Wheeler and Waterman equally provide residential care to their daughter, Wheeler was not entitled to an adjustment under Maine law.
Wheeler argued that the trial court's decision violated 19-A M.R.S. § 2006(5)(A), Maine's child support statute. This provision addresses how courts should handle child support calculations when a parent has additional children. Wheeler contended that the birth of his son should trigger an automatic adjustment to his support obligations, regardless of the shared custody arrangement with Waterman.
The Maine Supreme Judicial Court, in an opinion authored by Justice Mead, disagreed with the trial court's interpretation of the statute. The five-justice panel, which included Justices Mead, Connors, Lawrence, Douglas, and Lipez, concluded that the lower court misapplied Maine's child support law.
The Supreme Judicial Court found that the trial court's reasoning was flawed in denying Wheeler's request for adjustment. The court held that the equal residential care arrangement between Wheeler and Waterman does not automatically disqualify Wheeler from seeking a child support modification based on the birth of his new child.
The decision represents an important clarification of Maine's child support law, particularly in cases involving shared custody arrangements. The ruling suggests that courts must consider all relevant factors when determining child support obligations, including the birth of additional children, even when parents share equal residential time.
The case highlights the complexity of modern family law, where traditional child support models may not adequately address situations involving equal custody arrangements and blended families. The Supreme Judicial Court's interpretation of section 2006(5)(A) provides guidance for future cases involving similar circumstances.
Rather than issue a final ruling on Wheeler's support obligations, the Maine Supreme Judicial Court vacated the District Court's order and remanded the case for further proceedings. This means the case will return to the lower court, where the judge must reconsider Wheeler's request for adjustment in light of the Supreme Judicial Court's guidance.
The remand allows the trial court to properly apply the statute's requirements and consider whether Wheeler's child support obligation should be adjusted based on the birth of his son. The District Court will need to conduct a new analysis that takes into account the Supreme Judicial Court's interpretation of Maine law.
This decision could have broader implications for other parents in Maine who share equal custody but face child support obligations when they have additional children. The ruling clarifies that shared residential care arrangements do not automatically preclude consideration of support modifications when circumstances change.
The case was submitted on briefs on Oct. 29, 2025, and decided on Dec. 4, 2025. The relatively quick turnaround suggests the court viewed the legal issue as requiring prompt clarification given its potential impact on other pending family law cases throughout Maine's court system.