The Court of Appeals held in a decision on March 18, 2013, that all issues, including division of extra-curricular expenses, must be included in the final order. In that case, the Husband filed for a modification of support. The original divorce decree stated that Husband was to split extra-curricular expenses on top of paying child support. The final order on the modification simply awarded the Wife child support. Nothing was said about extra-curricular activities, but the Court did hold that all provisions of the divorce decree “not modified herein shall remain in full force and effect.” The Court of Appeals held that this statement did not apply to splitting extra-curricular activities because extra-curricular activities must either be included in the child support worksheet or specifically addressed. Given the expenses were not specifically addressed, they were no longer binding.
