Editor’s note: The author represented the appellant in Hanrahan v. Bakker.

The recent Pennsylvania Supreme Court case of Hanrahan v. Bakker, 186 A.3d 958 (Pa. 2018), a unanimous decision, and a case of first impression, changes the application of the high-income child support guidelines in Pennsylvania. Child support in Pennsylvania is governed by a statute and guidelines contained in the Pennsylvania Rules of Civil Procedure. Under the statute, 23 Pa. C.S. 4322, the child support guidelines are to be based on two main components: the ability of the payor to pay, and the reasonable needs of children. The child support guidelines are created from economic data pursuant to studies regarding the reasonable needs of children in intact households that are revised every four years. The child support guidelines are broken into two components. One component is a chart, and the other component is a three-step process. The chart applies to families that have a combined monthly net income up to $30,000. The reason that the chart stops at $30,000 combined monthly net income is that there is no reliable economic data regarding the reasonable needs of children in households where the combined monthly net income exceeds $30,000. Families who have a combined monthly net income in excess of $30,000 per month are considered high-income cases and have child support calculated based on the three-step process.