It is widely known that it is public policy is to ensure children receive the support they need from their parents. In the vast majority of cases, a child support obligation terminates when a child reaches the age of majority (age 18) or graduates from high school, whichever is later, however, the Superior Court of Pennsylvania, in the recent matter of Somerset County Children and Youth Services v. H.B.R., 155 A.3d 627 (Pa. Super. 2017), has addressed the atypical situation when a child reaches the age of majority yet still remains subject to a dependency order.
In H.B.R. the child-at-issue was put into placement following a dependency action. Consequent to the same, Children and Youth Services (CYS) filed a complaint for child support against the child’s father and, accordingly, an order for child support was entered. A little over two years after the child support order was entered, the father filed a petition to modify the child support order, requesting termination of the same, because the child, having reached the age of majority and graduated from high school, was emancipated. Despite reaching the age of majority and graduating from high school, the child voluntarily chose to remain in the custody of CYS until age 21, which is his right to do.
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