Child visitation and child support rights are independent rights and are not contingent upon the other. Appert v. Appert, 341 S.E.2d 342, 80 N.C.App. 27 (1986).
“Child support orders entered by a trial court are accorded substantial deference by appellate courts and our review is limited to a determination of whether there was a clear abuse of discretion.” Mason v. Erwin, 157 N.C. App. 284, 287, 579 S.E.2d 120, 122 (2003) (citation and quotation marks omitted). “To support such a reversal, an appellant must show that the trial court’s actions were manifestly unsupported by reason.” State v. Williams, 163 N.C. App. 353, 356, 593 S.E.2d 123, 126 (2004).
“The trial court is vested with discretion to make adjustments to the guideline amounts for extraordinary expenses, and the determination of what constitutes such an expense is likewise within its sound discretion.” Ferguson v. Ferguson, 238 N.C. App. 257, 265, 768 S.E.2d 30, 36 (2014).
The trial court is authorized to order a child support award “in such amount as to meet the reasonable needs of the child for health, education, and maintenance, having due regard to the estates, earnings, conditions, accustomed standard of living of the child and the parties, the child care and homemaker contributions of each party, and other facts of the particular case.” N.C.G.S. § 50-13.4(c) (2019).
Generally, both parents have an equal duty to provide support for their children. See Plott v. Plott, 313 N.C. 63, 68, 326 S.E.2d 863, 867 (1985) (“Today, the equal duty of both parents to support their children is the rule.”); see also N.C. Gen. Stat. § 50-13.4(b)the support of a minor child.”). However, while parents have an equal duty to support their children, “the equal duty to support does not necessarily mean the amount of child support is to be automatically divided equally between the parties. Rather, the amount of each parent’s obligation varies in accordance with their respective financial resources.” Plott, 313 N.C. at 68, 326 S.E.2d at 867.
“Child support payments are ordinarily determined based on a party’s actual income at the time the award is made.” Williams, 163 N.C. App. at 356, 593 S.E.2d at 126.
In determining the amount of a child support obligation, the judge must evaluate the circumstances of each family and also consider certain statutory requirements. Bowers v. Bowers, 141 N.C. App. 729, 731, 541 S.E.2d 508, 509 (2001).
The trial court is vested with wide discretion in deciding the allocation of such expenses on a child’s behalf:
[T]he Child Support Guidelines . . . include a generalized, cursory instruction concerning how the court ‘may’ structure the responsibility for these uninsured expenses [which] does not in any way alter the trial court’s discretion to apportion these expenses, described and applied in Tise, 107 N.C.App. at 150, 419 S.E.2d at 183. . . .[T]he Child Support Guidelines neither require the trial courts to follow a certain formula nor prescribe what the trial courts ‘should’ or ‘must’ do in this regard[.] . . . Given the wide discretion afforded[to]our trial courts in matters concerning the allocation of uninsured medical or dental expenses, then, such decisions cannot be disturbed on appeal absent a manifest abuse of discretion.
Holland v. Holland, 169 N.C. App. 564, 571–72, 610 S.E.2d 231, 236–37 (2005).