Michael Bertin Examines Child Support Reductions in Varied Custody Arrangements

In an August 11, 2026 article for The Legal Intelligencer, Michael Bertin, partner and co-chair of Obermayer’s Family Law Group, examines the Pennsylvania Superior Court’s decision in Mosher v. Mosher, __ A.3d __, 2026 Pa. Super. 122 (June 15, 2026).

Michael explains that the decision clarifies how Pennsylvania’s child support guidelines apply when parents have different custody arrangements for multiple children. The court held that custodial time must be averaged across all children when determining whether an obligor qualifies for a support reduction, rather than calculating each child separately. Because the father’s average custodial time was only 25%, he was not entitled to the reduction available when an obligor has more than 40% of annual overnights.

As the Superior Court explained, “an obligor is only entitled to a reduction based on custodial time if the obligor’s custodial time exceeds 40% in considering all children.”

The Mosher decision offers a useful reminder for family law practitioners and courts navigating the complexities of Pennsylvania’s child support guidelines, particularly when children have different partial or shared physical custody schedules.

Read the full article here.