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The recent Walker v Goodman [2024] case involving England footballer Kyle Walker and Lauryn Goodman has drawn attention to Schedule 1 of the Children Act 1989, which allows courts to make financial provisions for children whose parents are not married. This case exemplifies the extent of support the court can order when one parent’s resources far exceed those of the other. Although Walker’s support provisions, including £1,350,000 for housing and a maintenance budget of £12,500 per month, may seem high compared to typical cases, they highlight the court’s discretionary powers in addressing children's welfare in high-net-worth disputes.
Background: Walker v Goodman [2024]
Lauryn Goodman initially received provisions in 2022, including housing and living costs, but sought increased financial support as Walker’s income reportedly reached £7 million per year. While the court granted further support—totalling £150,000 annually plus funding for nannies, a vehicle, and necessary home modifications—it also denied what it deemed excessive requests for amenities like astro-turf and air conditioning, concluding that Goodman’s demands were inflated.
Key Provisions of Schedule 1 of the Children Act
Schedule 1 is designed to support children’s financial needs, not the lifestyle or support of the custodial parent. Its main applications include:
- Financial Maintenance: Parents with care responsibilities can apply for maintenance from the other parent. This usually continues until the child turns 18, but courts may consider extended support for children in full-time education or with disabilities.
- Lump Sum Payments and Property Transfers: Schedule 1 allows the court to order lump sums for housing, educational expenses, or other one-off needs. Property transfers may also occur but revert to the original owner once the child reaches adulthood.
Considerations for Court Decisions
In Schedule 1 applications, courts weigh:
- Parents' Financial Circumstances: This includes their current and future earning potential.
- Child’s Needs: The court assesses the child’s living standards during the relationship, considering if their welfare would suffer without additional support.
- Special Circumstances: Courts may consider disabilities, educational needs, and even the lifestyle of the higher-earning parent.
Flexibility and Transparency in Schedule 1
One unique aspect of Schedule 1 is its flexibility, which allows judges to tailor orders to varied family situations. This discretion, however, can make outcomes challenging to predict, as the court has wide-ranging power to address each case’s specifics.
In recent years, there has been a push for transparency, as seen in the Walker-Goodman case, where the judgment was published to provide insight into the Family Court’s approach in high-profile cases. This transparency underscores the balance the court must maintain between children’s welfare and the privacy of the family involved.
The Walker v Goodman case is a powerful illustration of Schedule 1’s capabilities, showing that courts can offer comprehensive support for children when financial inequality between parents would otherwise result in vastly different standards of living.
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The contents of this article are intended for general information purposes only and shall not be deemed to be, or constitute, legal advice, and should not be relied upon as advice. We cannot accept responsibility for any loss as a result of acts or omissions taken in respect of this article. All content was correct at the time of publishing. Legal advice should always be sought in relation to specific circumstances.