id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-20654	Higdon, Amy E.; Barry, Emily J.	Recent Developments in Indiana Family Law	2015	52	.pdf	application/pdf	22899	1151	58	The court of appeals did, however, reverse the trial court’s decision on the health insurance credit and application of Social Security Retirement benefits and both parties appealed.369 However, on transfer, the Indiana Supreme Court affirmed the trial court’s decision, acknowledging that, although individual courts may adopt different approaches when establishing a support obligation, when the Guidelines do not specify a bright-line procedure, courts must tailor child support orders based on the individual circumstances of the parties and apply the Guidelines to the circumstances with their best judgment, as the trial court did in this instance.370 In analyzing the calculation of mother’s health insurance credit, the Indiana Supreme Court cited language from Indiana Child Support Rules and Guidelines, Guideline 3(E)(2) and the corresponding commentary requiring that the children’s portion of the health insurance premium be credited, which gives rise to this issue on appeal.371 Here, father argued that the trial court’s calculation of the health insurance premium includes a portion for mother’s subsequently born child, but the supreme court held that although the trial court’s methodology may not have been the most mathematically accurate means to calculate the appropriate health insurance credit due to mother’s subsequently born child, the trial court used its best judgment in assessing the children’s health insurance premium.372 Father’s proposal for the health insurance credit, furthermore, was not a realistic option in light of the plans available through mother’s employer, as his request to base the credit consistent with an “employee plus one” policy would not cover mother and the parties’ two children even without considering mother’s subsequently born child.373 Father’s Social Security Retirement benefits were also a factor to be considered when establishing the new child support figure.374 With this issue, the 365. Id. at 408-09 (citing D.C. v. J.A.C., 977 N.E.2d 951, 956 (Ind. 2012) (referencing deference to trial courts in light of their unique, direct interactions with the parties face-to-face, over an extended period of time, thereby enabling trial courts to assess credibility and character).	cache/inlawrev-20654.pdf	txt/inlawrev-20654.txt