The Mississippi Court of Appeals recently made a significant ruling regarding child support and visitation rights in the case of William T. McLain v. Tristan Davis (Docket No. 2025-CA-00453-COA). The court's decision affects the custody arrangement for their minor child, K.D., born in May 2023, and addresses the responsibilities of both parents in this ongoing custody dispute.

In this case, the court ruled that McLain must pay $600 per month in child support to Davis. Additionally, the court allowed Davis to have sole discretion over visitation rights for McLain. This ruling is important as it sets a precedent for how child support amounts can be determined and how visitation rights can be granted in custody cases involving unmarried parents.

Background

William McLain and Tristan Davis are the natural parents of K.D. Although they were never married, their relationship has been contentious since the child's birth. In December 2023, the Mississippi Department of Human Services (DHS) filed a complaint to establish paternity and seek other relief. Shortly thereafter, Davis filed a petition for custody, supervised visitation, and child support.

The initial hearing on Davis's petition was delayed at McLain's request until September 2024. At that hearing, a temporary order was issued granting Davis temporary physical and legal custody of K.D. The order also required McLain to pay $350 per month in child support. This arrangement continued until a final hearing took place on March 5, 2025, where the court reviewed both Davis's petition and DHS's complaint.

The final hearing was informal, with both parties providing sworn statements without calling witnesses or allowing cross-examination. The chancellor ultimately increased McLain's child support obligation to $600 per month and granted Davis sole discretion over McLain's visitation rights. McLain appealed the decision, claiming it was unfair and unsupported by evidence.

The Ruling

The Mississippi Court of Appeals reviewed the case and found that the chancellor had erred in determining the amount of child support. The court stated, "The record does not meet the requirements of the statutes," and emphasized that the chancellor failed to provide a specific basis for the $600 monthly support amount. The court noted that McLain had not provided a clear financial picture, as his financial declaration lacked any income figures and showed only debt.

The court also highlighted that the chancellor did not adequately consider McLain's financial situation, including his claim of being homeless and unemployed. The court ruled that the child support amount must be re-evaluated and remanded the case back to the chancellor for further consideration. The judges involved in this ruling included Chief Justice Barnes, and Justices McDonald and Emfinger.

Regarding visitation, the court clarified that McLain was not denied visitation entirely; rather, the chancellor allowed Davis to determine the terms of visitation at her discretion. The court found no error in this decision, stating that it was within the chancellor's authority to ensure the child's best interests were prioritized.

Impact

This ruling has significant implications for future custody cases in Mississippi, particularly those involving unmarried parents. By emphasizing the need for clear evidence in determining child support amounts, the court has set a standard that requires chancellors to provide a detailed rationale for their decisions. This may lead to more equitable outcomes in similar cases, as parents will be better informed about the financial obligations they may face.

Additionally, the ruling on visitation rights reinforces the chancellor's discretion in determining what arrangements are in the best interest of the child. It indicates that courts may impose restrictions on visitation based on the parents' circumstances and the child's welfare.

What's Next

The case has been remanded to the chancery court for further proceedings regarding the child support amount. McLain may have the opportunity to appeal any future decisions made by the chancellor if he believes they are unjust. The court filing did not indicate any related cases pending at this time.