### FILED DEC 23,2014 In the Office ofthe ClerkofCourt WA State CourtofAppeals, Division III

INTHE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE INTHE MATTEROF THE ) PARENTAGE OF A.L., ) No. 31711-1-111 ) STATE OF WASHINGTON, ) ) Respondent, ) ) PUBLISHED OPINION v. ) ) ERINLEIGH ZASSO, ) ) Appellant, ) ) and ) ) LETICIALOPEZ, ) ) Defendant. ) FEARING, J.

- Must a parentwho equally shares residential placement ofhis child with the otherparentbe excused from paying child supportwhen the parent earns more than the otherparent and the otherparentreceives public assistance for the child? The trial court answered in the negative. We affirm. ErinZasso, father ofA.L., appeals the trial court's order directing him to pay $336 permonth for child support. He claims he shouldpayno support since he shares residential placement ofthe child with the mother, LeticiaLopez, who agreed he need notNo.31711-I-II1 

### In re Custody of A.I.

pay support. The State ofWashingtonprovides Lopez, with TemporaryAssistance for Needy Families (TANF) to supportA.L., and the State initiatedthis petition for modification ofsupport. FACTS OnApril 11, 2004, LeticiaLopez gave birthto A.L. Forthe first seven months of his life, A.L. lived in three different homes. He ultimately resided with his maternal grandmother after Erin Zasso, the father, assaulted Lopez, and Lopez served time injail for drug crimes. Followingthe domestic violence incident, Zasso had no contact with A.L. for a year and a half, despite beingpermitted supervised visitation. Since released fromjail, Lopezhas lived in a household with hermother and A.L. OnFebruary 27, 2006, the State ofWashington, who provided TANF supportto LeticiaLopez, filed a parentage action to establish ErinZasso as A.L.'s father. A.L.'s maternal grandmother filed a third-party custody action, which the trial court consolidated with the parentage action. OnFebruary 23, 2007, the trial courtgranted summaryjudgment, finding thatZasso fathered A.L., orderingZasso to make a support transferpayment, and ordering Zasso to pay back child support in the amount of $7,138.00

. OnMarch 2, 2007, the trial court entered a temporaryparenting planthat awarded Erin Zasso residential time with A.L. three nights perweek in an alternating pattern with

2No. 31711-1-III In re Custody of A.L.

A.L.'s maternal grandmother. The temporary plan afforded Zasso 43 percent ofthe residential time with A.L. OnMarch 23, 2007, Erin Zasso filed a motion to terminate his support obligation. The State did not objectto the termination because it no longerprovided TANF support to Leticia Lopez. OnApril 13,2007,the lower courtterminated Zasso's support obligation. The temporary parentingplan remained in place. In January 2012, the State resumed TANF payments toLeticiaLopez. PROCEDURE OnApril 25, 2012, based on LeticiaLopez's receipt ofTANF funds, the State of Washington filed this petitionto modify ErinZasso's child support obligation. On July 31, 2012, afterthe filing ofthis petition to modify, LeticiaLopez and Erin Zasso entered an agreed parentingplan in a different case. The plan and attendant order equally allocated A.L.'s residential time between Zasso and Lopez. Atthe modification hearing in the present matter, Erin Zasso argued thathis equal residential time with A.L. precluded the court from naming him as the obligor. He also complained that an imposition ofa transfer payment would unfairly placethe entire burden ofsupporting A.L. on him, particularly in light ofshared custody ofthe child. He emphasized that LeticiaLopez had agreed that he owed no child support. OnAugust 21,2012, the trial court issued rulings imposing transferpayments on Erin Zasso as a result ofthe TANF payments bythe State ofWashingtontoLeticia 3No. 31711-1-111 In re Custody of A.I. Lopez. In its orders, the court adopted the child supportworksheets provided by the State. The court determined Zasso's monthly net income at $1,911, and, because Lopez

was voluntarily unemployed, imputed her income at $1,351 per month. The trial court determined Zasso's contribution for A.L.'s support at $336 and Lopez's contribution at $187 per month. The trial court ordered no deviation from the standard calculation because Zasso requested no deviation. The court ordered Zasso to make a support transferpaymentto the Washington State Support Registry in the amount of$336per month, effective May 1, 2012. The trial court later denied motions for revision and reconsideration. LAW AND ANALYSIS STATEAUTHORITYFOR MODIFICATIONPETITION Erin Zasso first contends that the State ofWashington lacks the prerogative to seek a modification ofchild support obligations because Leticia Lopez, theparty receiving TANF benefits, is not the primary residential parent, since he equally shares custody ofthe minor child. We disagree. Ifthe State pays public assistance for the care and maintenance ofa child, the State maypursue a support action or apetition to modify support to obtain reimbursement ofmonies expended, in a process known as "subrogation." In re Parentage ofIA.D., 131 Wn. App. 207, 217,126 P.3d 79 (2006). In what could be considered excess, at least seven statutes confirm this authority. RCW 74.20A.030 4No.31711-I-II1 In re Custody of A.L. provides, in pertinentpart: (I) The [Department ofSocial & Health Services (DSHS)] shall be subrogated to the right ofany dependent child or children orperson having the care, custody, and control ofsaid child or children, ifpublic assistance money is paid to or for the benefit ofthe child, or for the care and maintenance ofa child

... , toprosecute or maintain any support action or execute any administrativeremedy existing under the laws ofthe state of Washingtonto obtain reimbursement ofmoneys expended, based on the support obligation ofthe responsibleparent established by a child support order. Distribution ofany support moneys shall bemade in accordance with RCW 26.23.035. RCW 74.20.330 demands that the recipient ofpublic assistance assign any rights he or she has to collect child supportto DSHS. RCW 74.20.330 prescribes: (1) Wheneverpublic assistance is paid under a stateprogram funded under Title IV-A ofthe federal social security act as amended by the personal responsibility and work opportunityreconciliation act of 1996, and the federal deficitreduction act of2005, each applicant orrecipient is deemed to have made assignment to the department ofany rights to a support obligation from any otherperson the applicant or recipient may have in his orher own behalfor in behalfofany other family member for whom the applicant orrecipient is applying for or receivingpublic assistance. (2) Payment ofpublic assistance under a state-fundedprogram, or a program funded under Title IV-A, IV-E, or XIX ofthe federal social security act as amended by the personal responsibility and work opportunity reconciliation act of 1996 shall: (a) Operate as an assignmentby operation oflaw; and (b) Constitute an authorization to the department to provide the assistance recipient with support enforcement services. The State may initiate "an action in superior court to obtain a support order or obtain otherreliefrelated to support for a dependent child on whose behalfthe department is providingpublic assistance." RCW 74.20.220(1). Under RCW 

### 5No. 3 1 711-1-III In re Custody of A.L. 74.20A.030(l): The department shall be subrogated to the right of any dependent child or children or person having the care, custody, and control of said child or children, ifpublic assistance money is paid to or for the benefit of the child, or for the care and maintenance ofa child. (Emphasis added.) The State ofWashington's authority to seek subrogation extends to the rightto file

apetition to modify support. RCW 26.09.170 reads: (9) The department ofsocial and health services may file an action to modify or adjust an order ofchild support under subsections (5) through (7) ofthis section if: (a) Public assistance money is being paid to or for the benefit ofthe child. RCW 26.09.l75 reads: (3) As provided for underRCW 26.09.170, the department ofsocial and health services may file an action to modify or adjust an order ofchild support if: (a) Public assistance money is being paid to or for the benefit ofthe child. Washington's version ofthe Parentage Act, chapter 26.26 RCW, prohibits the trial court from limiting or affecting the right ofthe State to seek reimbursement for support and services provided to the child. The relevantprovision reads: The court shall not limit or affect in any manner the right of nonparties including the state of Washington to seek reimbursement for support and other services previously furnished to the child. RCW 26.26.130(5). When the State pays TANF to one parent, but the court still requires the other 6No. 31711-1-111 In re Custody of A.L. parent to make a monthly support transfer payment, the money collected is used to reimburse the State for its expenditures for public assistance. State ex reI. Sigler v. Sigler, 85 Wn. App. 329, 337, 932 P.2d 710 (1997) (citing RCW 74.20A.030). The policy behind subrogation is to lessen the burden on the taxpaying public by demanding that parents help pay for the child's maintenance. Sigler, 85 Wn. App. at 337 (citing RCW 74.20A.OlO). The State has an interest in placing the primary responsibility for the

care and support ofchildren on parents rather than on the taxpayers. State v. Wood, 89 Wn.2d 97, 100,569P.2d 1148 (1977), abrogatedon othergrounds by, Sw. Wash. Chapter, Nat 'IElec. ContractorsAss 'n v. Pierce County, 100 Wn.2d 109,667 P.2d 1092 (1983); Sigler, 85 Wn. App. at 337. Erin Zasso contends two Washington regulations circumscribe the State's authority to petition for a support modification under his circumstances. WAC 388-l4A2030(1) reads: "A custodial parent applying for or receiving cash assistance on behalfof

a minor child assigns the family's rights to support as provided in WAC 388-14A-2035." In tum, WAC 388-14A-l020 defines a "custodial parent" as "the person, whether a parent or not, with whom a dependent child resides the majority ofthe timeperiod for which the division ofchild support seeks to establish or enforce a support obligation." Zasso reads the two regulations together to argue that the State's subrogation rights extend only when the parent receiving the benefits resides with the child more than half ofthe time. Based on a reading ofthe Washington statutes and other regulations, we 7No. 3 1 711-1-

### III In re Custody of A.L. disagree. RCW 26.09.170 and .175 allow the State ofWashington to request to modify an order ofchild support wheneverpublic assistance is paid to benefitthe child. We may admit that, under WAC 388-14A-1020, LeticiaLopez, the TANF recipient, is notthe custodial parent, or at least not the sole custodial parent, because ofsharedplacement of A.L. Nevertheless, Washington statutes do not limit the State's authority to file a modification to instances when the sole custodial parent is the recipient ofthe assistance. Because ofthe statutes demanding subrogation, in order for Zasso to prevail on his argument, he must show that some other statute orregulationprecludedLopez from receiving TANF assistance from the State. WAC 388-14A-1020 and WAC 388-14A2030 do not expressly preclude the assistance. Otherregulations allow, rather than disallow, public assistance even whenthe recipient shares residential placement with anotherparent. Underthe WAC child support scheme, assistance unit (AU) refers to "the group ofpeople who live together and whose income orresources [the State] count[s] to decide

... eligibility for [TANF] benefits and the amount ofbenefits." WAC 388-408­ 0005(1)(c). Pursuant to WAC 388-454-0005(2)(b) "[i]frelatives share physical custody ofthe child in equal amounts, [the State] include[s] the child in the AU ofthe parent or relative that first applies for assistance for the child." This latter regulation disassembles Zasso's contention. The parent who first applied here is LeticiaLopez. ErinZasso disregards the explicit language ofWAC 388-454-0005(2), whichpermits TANF 

### 8No.31711-I-II1 In re Custody of A.L. payments whenparents share equal custody oftheir children. The language ofWAC 388-454-0005(2) indicates the drafters contemplatedthe type ofshared custody parenting situation in the current case. Washington statutes and regulations directing the State ofWashington to collect support from a parent whose child receives TANF benefits fulfill federal TANF requirements under 42 U.S.C. 

### § 608(a)(3). The federal statute demands that a state, as a condition toparticipating in the TANF program, require each recipient to assign rights to collect child support. The statute does not condition assignment on the amount oftime a child spends with his orherparents. The State child support system, including the administrative scheme, statutory scheme, and public policy considerations, all negate Erin Zasso's argument that only custodial parents orparents whoreside with the child more than halfofthe time can subrogate supportrights to the State ofWashington. The State had the authority to file the petition to modity the support obligations ofErin Zasso. ZASSOASOBLIGOR WHENSHARINGRESIDENTIAL PLACEMENT The State ofWashington may be subrogatedto LeticiaLopez's rights to collect child support only ifLopez held the right to collect child support from ErinZasso. Therefore, Zasso identifies the principal question raised by his appeal to be whetherthe father should be required to make a transferpaymentto the mother when the two share custody ofthe child? Stated differently, may the court declare a parent who shares 9No. 31711-1-III In re Custody of A.L.

residential placement with the otherparentto be an "obligor" for purposes ofsupport transferpayments? Zasso claims Washington has yet to clearly articulate standards for determining who the obligor parent should be in cases ofshared custody. The legislature's stated intent in enacting legislation imposing child support transferpayments is "to insurethat child support orders are adequate to meet a child's basic needs and toprovide additional childsupport commensurate withtheparents' income, resources, and standard ofliving." RCW 26.19.001 (emphasis added). The legislature also intended that the child support obligation be "equitably apportioned between the parents." RCW 26.19.001 (emphasis added). In Washington, both biological parents have an obligation to support their children regardless ofmarital status. LindaD. v. Fritz 

## c., 38 Wn. App. 288, 300,687 P.2d 223 (1984). A parent's obligation for the care and support ofhis or her child is a basic tenet recognized in this state without reference to any particular statute. State v. Wood,89 Wn.2d at 100. When entering an order ofchild support, the trial courtbegins by setting the basic child support obligation. RCW 26.19.011(1); State ex rei. MMG. v. Graham, 159 Wn.2d 623, 627, 152 P.3d 1005 (2007). This obligation is determined from the statute's economic table, which is based on the parents' combined monthly net income, as well as the number and age oftheir children. RCW 26.19.011(1), .020. The trial court next allocates the child support obligation between the parents based on eachparent's share of 10No. 31711-1-III In re Custody of A.L.

the combined monthly income. RCW 26.19.080(1). The courtthen determines the standard calculation, which is the presumptive amount ofchild support owed by the obligorparent to the obligee parent. RCW 26.19.011(8); 

### Graham, 159 Wn.2d at 627. Erin Zasso emphasizes that RCW 26.19.011 fails to identify or establish any standards for who becomes the obligor orthe obligee. We concede the statutory scheme could be clearer in answering the question ofunderwhat circumstances one may become

an obligor. Nevertheless, we conclude the trial court held authority, under statutory

sources as well as recent Washingtonprecedent, to nominate Zasso as the obligor since he accrued the higher income and the mother received TANF benefits for the child, despite shared residential placement. After determining the standard calculation and nominating the obligor, the trial court, ifrequested, considers whether it is appropriate to deviate upward or downward from the standard calculation. RCW 26.19.011(4), (8). The court has discretion to deviate from the standard calculation based on such factors as the parents' income and expenses, obligations to children from otherrelationships, and the children's residential schedule. RCW26.19.075(1). Ifthe court considers a deviation based on residential schedule, it must follow a specific statutory analysis: The court may deviate from the standard calculation ifthe child spends a significant amount oftime with the parent who is obligated to make a supporttransferpayment. The court may not deviate on thatbasis ifthe deviation will result in insufficient funds in the household receiving the support to meetthe basic needs ofthe child or ifthe child is receiving 11No. 3 1 711-1-III In re Custody of A.L.
temporary assistance for needy families. When determining the amount of the deviation, the court shall consider evidence concerning the increased expenses to a parentmaking supporttransfer payments resulting from the significant amount oftime spent withthatparent and shall considerthe decreased expenses, ifany, tothe party receivingthe supportresulting from the significant amount oftime the child spends withthe parentmakingthe support transferpayment. RCW 26. 19.075(l)(d). Thetrial court must enter written findings offact supportingthe reasons for any deviation or denial ofa party's request for deviation. RCW 26.19.075(3); Graham, 159 Wn.2d at 627-28. A court's decision to deviate from the standard calculation for child supportbased on residential time is discretionary, butthe court cannot deviate ifit will result in insufficient funds in the householdreceivingthe support, or ifthe child is receiving TANF. RCW 26.19.075(1)(d); In re Marriage of Rusch, 124 Wn. App. 226, 236,98 P.3d 1216 (2004), abrogatedon othergrounds by, In re Marriage of McCausland, 159 Wn.2d 607, 152 P.3d 1013 (2007). After determining the standard calculation and any deviations, the trial courtthen orders one parentto pay the other a support transferpayment. RCW 26.19.011(9). Erin Zasso never sought a deviation from the standard calculation. Granting a deviation mayhave been an abuse ofdiscretion because ofthe motherreceiving TANF benefits and having no otherincome. Theresidential schedule deviation was added tothe child support schedule in 1991. LAWS OF 1991, 1st Spec. Sess., ch. 28, 

### § 6. Before 1991, the Washington Child 12No. 31711-1-111 In re Custody of A.L. Support Guidelines allowed for a residential credit ifthe child resided overnight with both parents more than 25 percent ofthe time. Helen Donigan, Calculating and Documenting ChildSupportAwards Under Washington Law, 26 GONZ. L. 

### REv. 13,45 (1991). A separate worksheet provided space for determining the residential credit for each parent. Donigan, supra, at 45. This special worksheet also applied to cases where parents splitresidential time. Donigan, supra, at 45-46. The legislature did not retain this formula for residential credit against child support with the 1991 addition ofstatutory deviations. See RCW 26.19.075(l)(d); In re Marriage of Schnurman, 178 Wn. App. 634, 639-41,316 P.3d 514 (2013), review denied, 180 Wn.2d 1010,325 P.3d 914 (2014). The change in legislation suggests an intentto afford wider discretion to the trial court when considering a deviation for residential credit. This court reviews a trial court's order ofchild support for abuse ofdiscretion. In

re Marriage of Griffin, 114 Wn.2d 772, 776, 791 P.2d 519 (1990); In re Marriage of Schnurman, 178 Wn. App. at 638. A trial court abuses its discretion ifits decision rests

on unreasonable oruntenable grounds, or ifit bases its ruling on an erroneous view ofthe law or involves incorrect legal analysis. Dix v. ICTGrp., Inc., 160 Wn.2d 826, 833, 161 P.3d 1016 (2007); Schnurman, 178 Wn. App. at 638. The legislature intended to allow judicial discretion in appropriate circumstances when calculating child supportpayments, and a reviewing court must defer to the sound discretion ofthe trial court unless the lower court abused its discretion. In re Marriage of Griffin, 114 Wn.2d at 776. 13No. 31711-1-III In 

### re Custody of A.L. Recently, both the Washington Supreme Court and the Court ofAppeals addressed the applicability ofthe standard child support schedule to cases ofequally shared custody, such as the one currently at issue. The well-reasoned decisions compel denial of Erin Zasso's appeal. In 

### State ex reI. MMG. v. 

### Graham, 159 Wn.2d 623, 152 P.3d 1005 (2007), the Washington Supreme Court decided a custody case in which the parents evenly shared residential placement oftheir children. The father's income exceeded the mother's

revenue by over $4,000 per month, and the trial court named the father as the obligor, requiring that he make a transferpayment to the mother. On appeal, the father in 

### Graham argued that chapter 26.19 RCW did not adequately guide trial courts in determining parents' child support obligations when the parents shared equal custody and urged the court to adopt a new standard. The Supreme Court disagreed, and stressed that RCW 26.19.075 already provided trial courts with the discretion to deviate from the standard calculation, based on the residential schedule deviation found in RCW 26.19.075(l)(d). 

### Graham, 159 Wn.2d at 636. Relying on RCW 26. 19.075(l)(d), the Supreme Court explained, "[b]ecause the statute explicitly gives the trial court discretion to deviate from the basic child support obligation based onthe facts ofa particular case, a specific formula is neither necessary nor statutorily required to

ensure the parents' child support obligation is properly allocated." 

### Graham, 159 Wn.2d at 636. The court in 

### Graham clarified that the trial court must still use the standard child 14No. 31711-1-II1 In re Custody of A.L. support schedule and statutory deviations in cases ofshared custody. Graham, 159 Wn.2d at 636. More recently, Division One ofthis court addressed a case ofshared custody in In

re Marriage of Schnurman, 178 Wn. App. 634,636,316 P.3d 514 (2013), review denied, 180 Wn.2d 1010,325 P.3d 914 (2014). 

### In Schnurman, the parentingplan dictated that the parents "share equal residential time with the children throughout the year." Schnurman, 178 Wn. App. at 637. The trial court first calculated the parents' child support obligation and found that the father's monthly net income was $6,338 and the mother's was $3,380. Schnurman, 178 Wn. App. at 637. Although the couple shared custody oftheir children, the trial court named the father as the obligor and required that he make a transferpaymentto the mother. Schnurman, 178 Wn. App. at 637. The father requested a downward deviation from the standard calculation, but did not characterize it

as a residential credit, instead arguing that the statutory deviations did not apply to cases ofshared custody. Schnurman, 178 Wn. App. at 637. The trial court dismissed the father's argument, while noting the absence ofevidence that the father's shared time with the children would significantly increase his costs to supportthe children or reduce his wife's expenses to support the children. Schnurman, 178 Wn. App. at 637. The father inSchnurman, like Erin Zasso, also argued that only parents with whom children spend the majority oftheirresidential time are entitled to a support transferpayment. Schnurman, 178 Wn. App. at 638. The court dismissed the father's 15No. 31711-1-III 

### In re Custody of A.L. contention, stating that RCW 26.19.075, the statute governing deviations, applies in shared residential situations. 

### Schnurman, 178 Wn. App. at 637 n.4. Relying on the Supreme Court's holding in 

### Graham, the 

### Schnurman court specified "that the statutory child support schedule applies in shared residential situations like here." 

### Schnurman, 178 Wn. App. at 638 (citing 

### Graham, 159 Wn.2d at 626). After describing the general child support determinationprocess, the court explained the deviation procedure. 

### Schnurman, 178 Wn. App. at 640. The courtnoted that a trial court may deviate when children share residential time equally between parents, but "adeviation would still be discretionary and should focus on the legislature's primary intentto maintain reasonable support for the children in each household." 

### Schnurman, 178 Wn. App. at 641 (citing

### State ex rei. MMG. 

### v. Graham, 123 Wn. App. 931, 933, 99 P.3d 1248 (2004). As in 

### Graham, the courtrefused to set forth a formula for 

### 50/50 shared custody obligation determinations. 

### Schnurman, 178 Wn. App. at 642. The court explained that the child support schedule still applies in cases ofshared custody; thus, RCW 26.l9.075(l)(d) already provides trial courts with the discretion to deviate based on residential time, precluding the need for a specialized formula. 

### Schnurman, 178 Wn. App. at 642. As in 

### Graham and 

### Schnurman, this case involves a case ofevenly splitresidential placement. Consistent with both 

### Graham and 

### Schnurman, the superior court in this case used the standard support schedule to allocate the support obligation between Erin Zasso and LeticiaLopez, as well as to name Zasso as the support obligor. The trial court's 16No.31711-1-II1 In re Custody of A.L.

determination ofZasso's support obligation was consistent with the statutory scheme and Washington case law. Despite these precedents, Erin Zasso argues that he cannotbe the obligorbecause Washington law lacks aprocedure for identifYing the obligor in equal custody cases. The father inSchnurman raised this same argument, claiming thathe was not seeking a downward deviation based on residential time. Division One explicitly rejected this argument. Schnurman, 178 Wn. App. at 637 nA. Erin Zasso contends that the holding ofSchnurman is inapposite because the father in Schnurman claimed that the support schedules simply did not apply under shared placement circumstances. Zasso distinguishes his argument as one of contending no transfer can be ordered because he is not an obligor. According to Zasso, he does not maintain that the child support schedule does not apply. He simply argues that when two parties share equal visitation, there mustbe a reasoned basis for ordering one parent to make a support transferpaymentto the other. We considerthis distinction to lack any legal relevance. Under both situations, the parent seeks to avoid payment ofchild supportbecause ofshared custody. Anyway, the TANF benefits and Zasso's higher income is a reasoned basis for isolating Zasso as the obligor. Nowhere does the statutory scheme or supporting case law state the parent receiving the support transferpayment mustbe the parent with whom the child resides a majority ofthe time. There is also no statutory provision, orcase law, which prohibits a 17No. 31711-1-111 In re Custody of A.L.

transfer payment from the advantaged parent to the disadvantaged parent in an equally shared residential arrangement. Finally, Erin lassorelies on In re Marriage of Holmes, 128 Wn. App. 727, 117 P.3d 370 (2005) to supporthis contention that chapter 26.19 RCW does notprovide for whether one parent should make a support transferpayment in shared custody cases. The court in Schnurman resolvedHolmes' applicability to cases ofshared custody when it stated: [R]eliance onIn re Marriage of Holmes, 128 Wn. App. 727, 117 P.3d 370 (2005), does not compel a different conclusion. Holmes did not involve a 50/50 sharedresidential situation like here. The Holmes court simply held that the trial court acted within its discretion in terminating the father's child support obligation. Though the father made significantly more money than the mother, the residential schedule had changed and the son resided a majority ofthe time with the father. Schnurman, 178 Wn. App. at 642 n.6 (internal citations omitted). lasso's use ofHolmes is misplaced. CONCLUSION We affirm the trial court's order compelling Erin lassoto pay a support transfer payment to the State ofWashington byreason ofhis child's receipt ofTANF benefits.

Fearing, J.

.

# w~~(~O=**~)&** Siddoway, C.

. Brown, J. 18