“Good fortune” child support is the name given to child support awarded above the amount specified in the child support guidelines. When the court awards good fortune support, it is requiring the payor-parent to pay more than required under the guidelines in order to meet the child’s needs. Boyt v. Romanow, 664 So. 2d 995, 996 (Fla. 2d DCA 1995), citing Miller v. Schou, 616 So. 2d 436 (Fla. 1993). Good fortune child support is based on the concept that the child benefits from the support-paying parent’s success and affluence. Id.
The amount of support provided for in the child support guidelines “is sufficient to cover the bare necessities of a child.” Id. at 997. To determine the amount of good fortune support, compare the amount of the actual needs of the child to the amount in the support guidelines. Id. Examples of expenses covered by good fortune support include “private schooling, special activities, or other amenities which go beyond bare necessities.” Id. at 997, citing Miller v. Schou, 616 So. 2d 436, 438 (Fla. 1993).
Good fortune child support takes in to consideration the lifestyle of both biological parents. In Smith v. Smith, the Second District held that a child is entitled to share in the good fortunes of both parents. Smith v. Smith, 474 So. 2d 1212 (Fla. 2d DCA 1985), review denied, 486 So. 2d 597 (Fla. 1986). Courts have applied the concept of good fortune child support to increase a support award after the support-paying parent received a substantial increase in earnings. See Miller v. Schou, 616 So. 2d 436, 438 (Fla. 1993)(holding that an increase in the ability to pay is itself sufficient to warrant an increase in child support).
Good fortune support has its limits. In Miller v. Schou, the Florida Supreme Court noted that “[t]he child is only entitled to share in the good fortune of his parent consistent with an appropriate lifestyle.” Similarly, in Taylor v. Taylor, 734 So.2d 473 (Fla. 4th DCA 1999), the Fourth District refused to modify child support despite the father’s substantial wealth, noting that the children lacked nothing. In the Third District, in order for a petitioning parent to receive an increase in child support, courts have required both an increase in the ability to pay as well as an increase in the child’s needs which may be met only by increasing the amount of support. Shufflebarger v. Shufflebarger, 460 So. 2d 982, 984 (Fla. 3d DCA 1984); Young v. Young, 456 So. 2d 1282, 1284 (Fla. 3d DCA 1984).