This page chronicles the discriminatory practice of states requiring a parent to pay child support on a child who is 18 years or older. These laws permit a burden to be imposed upon one class of citizens---divorced or separated parents---that cannot in like circumstances be imposed upon married parents residing together.

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NEWS

Oregon's Crocker v. Crocker update, 11-22-99

The Supreme Court of the State of Missouri has ruled against a father, Steven Snodgrass, in the case with his ex-wife on the issue of continued child support after age 18. (Supreme Court Ruling) 8-24-99

Let us all encourage the Father, Steven Snodgrass, and his attorney, Jack Cavanagh, to carry the case on to the US Supreme Court with what ever help that they need. Furthermore, let us encourage Missouri Fathers to take the issue to their Legislature for correction.

The Statutes for these States do not reflect Court decisions:
Without a specific State Statute, Courts may give an opinion or decision that says Child Support should be paid beyond age 18 giving a "common law", or "case law" interpretation.

Currently, 7 States statutorily forbid "post-secondary education" child support. They are:

Kansas.........KS 60-1610
Louisiana.......RS 9=309
Maine ..........MRS. 19s 303
North Dakota. NDCC-08-0
Oklahoma......O S 10 ss 16
Vermont....... .T 15 ss 658
Wisconsin ....767.25

There are 15 States with case laws forbidding "post-secondary Education" child support. They are:

Alaska,.......679 P2d 480 (1984)
Arizona,......575 P2d 1243 (1978)
Delaware,....??? A2d 924 (1973)
Florida,........450 S2d 853 (1984)
Georgia,.......260 SE2d 871 (1979)
Idaho,.......... 184 P 470 (1919)
Kentucky,.....282 SW2d 146 (1955)
Montana,......589 P2d 148 (1979)
New Mexico,..666 P2d 781 (1983)
North Carolina,..330 SE2d 57 (1985)
Ohio,..............477 NE2d 648 (1984)
Pennsylvania,..616 A2d 628 (1992) - see below
Rhode Island,..391 A2d 79 (1978)
South Dakota,...417 NW2d 891 (1988)
Virginia,........... 261 SE2d 52 (1979)

Pennsylvainia's Supreme Court struck down a provision that allowed child support over 18 in Curtis v. Kline.

11 States have restrictive laws for child support after "post-secondary education". They are:

Alabama
Colorado
Iowa (to age 22 only)
Maryland
Massachusetts
Michigan (to age 21 only)
Minnesota
New York
Oregon - see below
Texas
Utah

Oregon - In September of 1997 a Multnomah County judge ruled it is unconstitutional to require a divorced Portland father to help pay for his daughter's college expenses, and the case is currently on appeal.

7 States are silent on the issue of continued child support beyond "post-secondary" education. They are:

Arkansas
Hawaii
Indiana
Nebraska
Nevada
New Hampshire
West Virginia

Finally, 10 States allow for "post-secondary" education child support. They are:

California
Connecticut
Illinois
Mississippi
Missouri
New Jersey
South Carolina
Tennessee
Washington
Wyoming