M sought award of childcare costs related to her seeking a paralegal certificate. M was already employed in temporary and part-time employment. However, that employment was inconsistent and required M to rely on public assistance. F opposed request on grounds FC 4062 did not apply as M was already employed and was not required by her current employer to pursue paralegal studies. Trial court agreed with F and denied request. Reversed. Addressing an issue of first impression, the Court of Appeal determined that the mandatory add-on for childcare costs related to a parent’s “reasonably necessary or training for employment skills” under FC 4062 “sets forth no qualifying limitations.” Decision distinguishes Marriage of Khera & Sameer (2012) 206 Cal.App.4th 1467 as childcare costs in that action were sought even though party was self-supporting and was pursuing “elective education.”

Grenier v. Keller
6/14/19, CA 1/3:  A154755