A Florida appellate court has overturned part of an Okeechobee County divorce decree after a trial judge used an unsupported six-figure income to set child support without explaining where the number came from.
In an opinion issued July 29, 2026, the Fourth District Court of Appeal reversed the child support decision in the case of Jennifer C. Mathis v. Charles Jason Mathis, sending the matter back to the circuit court to properly establish income and recalculate support. The appellate panel affirmed all other aspects of the divorce judgment without additional comment.
During the trial in the Nineteenth Judicial Circuit, Jennifer Mathis testified that she worked about 20 hours per week as an employee making $55 per hour, bringing in between $2,200 and $2,500 biweekly—or roughly $57,200 annually.
Her updated financial affidavit listed a gross monthly income of $4,960.83, which comes out to roughly $59,530 per year.
Despite that evidence, Circuit Judge Leatha Dawn Mullins entered a supplemental final judgment using an annual gross income figure of $111,516 for Jennifer Mathis to calculate child support. Based on that figure, the trial court ordered that neither parent pay child support.
Writing for the appellate court, Judge Shaw pointed out that the trial judge gave no rationale or evidentiary backing for the much higher income amount. Under Florida law, courts can impute income—assigning higher earnings if a parent is voluntarily underemployed—only if specific factual findings are placed on the record. However, Judge Mullins had explicitly stated in her judgment that she was not imputing income to either party.
“Because the supplemental final judgment does not identify the evidentiary basis for the wife’s income, meaningful appellate review is impossible, and the resulting child support award is unsupported by competent, substantial evidence,” Judge Shaw wrote. Judges Gerber and Forst concurred in the ruling.
The appellate opinion also highlighted an issue in the paperwork submitted by Charles Jason Mathis, who represented himself without an attorney. The court noted that his answer brief cited two legal cases that do not exist.
Addressing the non-existent citations, the court reminded litigants of their responsibility to verify legal research, particularly when using digital tools.
“Such phantom authority cannot assist any litigant and must be expressly disregarded by this court,” the opinion stated. “Attorneys and those, like appellee, who proceed pro se are responsible for the content of their submissions to the court. Those who use artificial intelligence to assist in these submissions must ensure their accuracy.”
The case now returns to the circuit court to determine Jennifer Mathis’s actual income based on the record and recalculate child support accordingly.
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