top of page
Writer's pictureDavid Brewster

Claiming Hardship?

Updated: Apr 19

Notoriously hard to win these arguments, but it's not impossible.



As in most things, you don't have to look much farther than the statues and rules to see a framework you must follow to successful argue (or defend against) a particular claim. The Federal Child Support Guidelines give you the framework for a Hardship claim to prevail. Specifically s.10(3) and s.10(4) along with schedule II.


Let's take these hypothetical facts:

  • Mom's household income is $109,432

  • Dad's is $30,00

  • 3 Kids

  • Child Support at $30 and 2 kids is $621 x 12 = $7,452

  • Mom has primary care so the Low Income Measurement Amount in Schedule II :

    • Mom's household with 1 adult 3 kids $20,764

    • Dad's household with 1 adult $10,382


Mom's Household

Dad's Household

Income

$109,432

$30,000

Minus tax and deductions

($34,343)

($nil)

Plus Child Support Payable

$7,452

($7,452)

Household income

=$82,541

=$22,548

Low Income measures amount from Schedule II

$20,764

$10,382

Ratio Income / L.I.M.A. (standard of living)

3.98

2.17

To get that final ratio income, divide the Low Income Measures Amount from Schedule II by Household income. So 82,541 / 20,764 = 3.98.


The two bottom numbers show a standard of living ratio. The household with the higher ratio, has the higher standard of living. This is your starting point to a claim. If those numbers are close, your claim may not prevail. If they are far apart, you have a chance.


These specific numbers did result in a successful hardship claim by the Dad.


There are all sorts of additional considerations into these numbers:

Premi v. Khodeir and Toews v. Toews : It is not sufficient to rely on a large discrepancy between household income ratios as a circumstance constituting undue hardship. Where the discrepancy forms a large part of the hardship claim, the surrounding facts must be closely examined.


Poirer v. Poirer : No undue hardship results from high access costs.


Balo v. Motlagh : Undue hardship will not be presumed simply because of a payor's legal responsibility for other children or because his or her standard of living is lower than that of the other spouse or partner.


Bedard v. Bedard : The Wages Act states that a man should have at least half his disposable income, as that is defined, for his own support.


Walker v. Rutledge : if a payor parent does not meet the threshold of 40% of the time with the children, he or she cannot base a claim for undue hardship on the ordinary expenses incurred during access visits.


There is a long list of case law and considerations around hardship claims. This post is not meant to be exhaustive, but rather to give you a launching point from the calculations provided within the guidelines.



445 views0 comments

Recent Posts

See All

Comments


Law

STAY IN THE KNOW!
Get Notified when a new Post is Published.

Thanks for submitting!

bottom of page