Bring the receipts. That was the direction provided by Justice Latimer in a pair of related judgements released earlier this year. V.D.C. v. R.J.F.C., 2026 BCSC 311 and V.D.C. v. R.J.F.C., 2026 BCSC 1126 involved a mother’s application for child support with respect to her and her former spouse’s adult daughter.
The parties married in 2005 and separated in 2015. The parties entered into a series of separation agreements and consent orders respecting parenting time and child support following separation. In the daughter’s last year of high school, the mother had more than 60% of parenting time with the daughter. After the daughter graduated high school, she took a gap year and raised money working as a restaurant hostess before enrolling in a Bachelor of Fine Arts program at the Alberta University of the Arts in September 2025. The mother’s application for ongoing for child support was first heard in February 2026.
There are three questions in the adult child support analysis:
- Is there a reason why the child cannot withdraw from their parent’s care?
- If so, is the amount of child support provided for in the Federal Child Support Guidelines tables inappropriate?
- If so, what level of support is appropriate given the circumstances, means, and needs of the child, and the parent’s respective ability to provide support.
Justice Latimer had no difficulty providing an affirmative answer to the first two questions. The daughter was enrolled in a full-time program of study, and the completion of the program was an essential component of a realistic career plan. The daughter could not withdraw from the mother’s care as a result. On the second question, quantifying the support obligation with the assistance of the Guideline tables was inappropriate, because the daughter’s day-to-day circumstances did not reflect those of a minor. The daughter lived on an out of province campus during the school year.
Justice Latimer ultimately concluded that there would be no ongoing child support payable at all, because the mother had failed to tender sufficient evidence that would allow the Court to properly assess the means, needs, and circumstances of the daughter. There was not enough evidence before the Court to answer the third question.
In reaching this decision, Justice Latimer highlighted the mother’s failure to provide evidence regarding the daughter’s income during her gap year, the daughter’s plans to earn income during her 4-month summer holidays, or the availability of government student loans, scholarships, and bursaries. The mother did provide a loose estimate of the daughter’s monthly budget during the academic year. However, this budget was not detailed, and the mother did not tender any receipts to verify the accuracy of the estimate that she had made.
This case provides an important lesson for parents seeking child support for adult children who are enrolled in a post-secondary institution. The court will not order child support unless there is sufficient evidence to perform an assessment of the child’s means, needs, and circumstances. In other words, you need to bring the receipts when seeking child support for an adult child. This may include:
- the child’s employment records, tax returns, and monthly bank statements;
- letters of approval for government or private student loans;
- academic transcripts;
- club membership fees;
- semester schedules;
- lists of available bursaries and student loans from a campus career services office; or
- receipts for costs incidental to attending a post-secondary institution such as bus and parking passes, textbooks, lab equipment, compulsory student health and dental insurance plans, laptops and software, or fees for off or on campus tutoring.
There may be many other expenses specific to your child’s circumstances. Parental support obligations become more complicated when a child reaches the age of majority. If you have questions about support obligations for adult children, the lawyers in Nixon Wenger’s family law department are here to help.
Written by Henry Wearmouth, Family Law Lawyer
