Matter of Clara C. v. William L

In Matter of Clara C. v. William L. (96 N.Y.2d 244 [2001]) a child had been born out of wedlock in 1983 and the parties had entered into a compromise agreement after the mother had commenced paternity proceedings in 1986. The child's mother subsequently brought an application for increased support stating that the child's educational needs could not be met. While the parties in that case had not been allocuted as to the terms of the agreement or the circumstances under which the agreement had been entered into, the case did not turn on that point. The Court of Appeals determined that the Family Court Judge who approved the compromise agreement had not made inquiry as to whether the terms of the compromise agreement made adequate provision for the child. The Court of Appeals held that since no inquiry had been made as to the adequacy of the support provisions for the child, Family Court Act 516 (c) could not be invoked as a bar to the application for increased support (id. at 250). The Court of Appeals noted in Clara C. v. William L. (at 250) that Family Court Act 516 does not set forth a standard for the courts to use when attempting to determine whether or not the support provisions of the compromise agreement are adequate. However, the Court determined that the courts had looked at "the parties' financial positions, the child's support and educational needs throughout childhood and the interests of the State" (id. at 250). In addition, the Court held that "a court must determine the fairness and adequacy of a proposed agreement before approving it (Family Ct Act 516 [a]). Absent judicial review and approval, the agreement will not be enforced to preclude a later modification of support." (Id. at 250)