Kyei v. Division of Child Support

An order terminating existing license suspensions stemming from a child support judgment does not prevent future child support enforcement orders.

Petitioner sought judicial review of an administrative law judge’s (ALJ) final order upholding the Division of Child Support’s suspension of his driver’s license due to “child support arrearage.” Petitioner argued that a 2013 order that cleared existing license suspensions and stated that no further suspensions shall be issued except by the court precluded the enforcement of future judgments for child support and the license suspension at issue here. An order terminating existing license suspensions stemming from a child support judgment does not prevent future child support enforcement orders. The Court found that the current judgment is different from the judgment at issue in the 2013 order, has never been stayed, and therefore remains effective. The Court stated that those facts formed a sufficient basis for the ALJ to determine that Petitioner owed child support and found substantial evidence to allow the ALJ’s conclusions that led to the suspension of Petitioner’s licenses.