Ark. Code Ann. » Title 9 Chapter 14
Arkansas Code Annotated

Ark. Code Ann. § 9-14-237 (2026)

Expiration of child support obligation

✓ current as of May 2026
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    1. Unless a court order for child support specifically extends child support after these circumstances, an obligor's duty to pay child support for a child shall automatically terminate by operation of law:
      1. When the child reaches eighteen (18) years of age unless the child is still attending high school;
      2. If the child is still attending high school, upon the child's high school graduation or the end of the school year after the child reaches nineteen (19) years of age, whichever is earlier;
      3. When the child:
        1. Is emancipated by a court of competent jurisdiction;
        2. Marries; or
        3. Dies;
      4. Upon the marriage of the parents of the child to each other; or
      5. Upon the entry of a final decree of adoption or an interlocutory decree of adoption that has become final under the Revised Uniform Adoption Act, § 9-9-201 et seq., and thereby relieves the obligor of all parental rights and responsibilities.
    2. However, any unpaid child support obligations owed under a judgment or in arrearage pursuant to a child support order shall be satisfied pursuant to § 9-14-235.
    1. If the obligor has additional child support obligations after the duty to pay support for a child terminates, then either the obligor, custodial parent, physical custodian, or the Office of Child Support Enforcement of the Revenue Division of Department of Finance and Administration, within thirty (30) days subsequent to the expiration of the ten-day period allowed for the notification as provided in subdivision (b)(5) of this section, may file a motion with a court of competent jurisdiction requesting that the court determine the amount of the child support obligation for the remaining children.
    2. The remaining obligations, subsequent to the expiration of the thirty-day period contained in subdivision (b)(1) of this section, shall be adjusted by operation of law to an amount to be determined by using the most recent version of the family support chart pursuant to § 9-12-312(a)(3) for any remaining children for whom an obligation for child support exists.
    3. If the most recent child support order either was entered prior to the adoption of the family support chart by the Supreme Court or the support amount, as indicated by the order, deviated from the family support chart, then the issue of the amount of the obligor's child support obligation shall be decided by a court of competent jurisdiction.
      1. In the event a review is requested, the court shall apply the family support chart for the remaining number of children from the date of the termination of the duty, subject to any changed circumstances, which shall be noted in writing by the court.
      2. Deviation from the family support chart shall be noted in the court order or on the record, as appropriate.
      1. The obligor shall provide written notification of the termination of the duty of support to the custodial parent, the physical custodian, the clerk of the court responsible for receipt of the child support payments, the obligor's employer, if income withholding is in effect, and the office, if applicable, within ten (10) days of the termination of the duty of support.
      2. The obligor shall enclose with the written notification of termination a copy of the most recent child support order.
      3. The notification shall state the name and age of each child for whom the obligation to pay child support has ceased and the name and age of children set out in prior terminations of child support made pursuant to this subsection.
  3. No statute of limitations shall apply to an action brought for the collection of a child support obligation of arrearage against any party who leaves or remains outside the State of Arkansas with the purpose to avoid the payment of child support.

History. Acts 1993, No. 326, § 1; 1999, No. 1075, § 1; 2003, No. 1020, § 7; 2007, No. 337, § 1; 2009, No. 635, § 1.

Amendments. The 2007 amendment, in (a)(1)(A), added (ii) and made related changes, and substituted “unless the child is still attending high school” for “or should have graduated from high school, whichever is later” in present (i).

The 2009 amendment inserted (a)(1)(D) and made related changes.

Cross References. For child support enforcement guidelines, see the Appendix at the end of this subtitle.

Research References

Ark. L. Rev.

The Case for Expanding Child Support Obligations to Cover Post-Secondary Educational Expenses, 56 Ark. L. Rev. 93.

Brittany Horn, Case Note: Who's Your Daddy? State v. Perry and Its Impact on Paternity and the Rights of Adjudicated Fathers in Arkansas, 66 Ark. L. Rev. 1059 (2013).

U. Ark. Little Rock L.J.

Legislative Survey, Family Law, 16 U. Ark. Little Rock L.J. 131.

U. Ark. Little Rock. L. Rev.

Annual Survey of Case Law, Family Law, 28 U. Ark. Little Rock L. Rev. 739.

Case Notes

Applicability.

Where parties' eldest son turned 18 on July 5, 1992, husband's child support obligation continued under § 9-14-234; however, under this section, husband's child support obligation for that son terminated by operation of law on August 13, 1993, the effective date of this section, and the chancellor erred in awarding child support arrearage for eldest son beyond that date. James v. James, 52 Ark. App. 29, 914 S.W.2d 773 (1996).

Recalculation of support, based on the reduced value set forth in the family support guidelines for one child after an older child turned 18, was not an improper attempt to retroactively modify a judgment. Mixon v. Mixon, 65 Ark. App. 240, 987 S.W.2d 284 (1999).

A chancellor did not err by calculating a reduced amount of arrearage owed by the noncustodial parent by taking into account those child-support obligations that terminated by operation of this section upon the graduation from high school of the parties' children. Office of Child Support Enforcement v. Tyra, 71 Ark. App. 330, 29 S.W.3d 780 (2000).

Where father agreed to pay child support in the amount of $1,200 per month, which was above the amount required under the child support chart, so that the mother could use child support funds to pay tuition for both children to attend private school, appellate court held that the “child support” provision and the “college expenses” provision of the decree had to be read together, and concluded that it was the intent of the parties that the father's child support obligation would cease upon each child reaching the age of majority; however, if a child chose to attend college, the parties then agreed to share the expense of supporting the child while in college. Harris v. Harris, 82 Ark. App. 321, 107 S.W.3d 897 (2003).

Agreements.

Where a mother and the Office of Child Support Enforcement entered into a proposed agreement regarding child support arrearages after the parties' son reached the age of 18 and custody of their daughter was changed to the father, it was not error to refuse to follow the agreement, because the trial court was not bound by an independent agreement concerning child support and the trial court retained jurisdiction over child support. Roark v. Office of Child Support Enforcement, 101 Ark. App. 382, 278 S.W.3d 114 (2008).

Child With a Disability.

Circuit court properly concluded that the father's child support obligation for a child with a disability did not terminate automatically when the child turned 18 and graduated from high school as this section did not automatically terminate the continuing, common-law duty to support a child with a disability. Guthrie v. Guthrie, 2015 Ark. App. 108, 455 S.W.3d 839 (2015).

This section sets forth the general rule that parental support automatically ceases when a child reaches the milestones that traditionally signal emancipation. However, the statute does not automatically terminate a parent's continuing, common-law duty to support a child with a disability upon attaining his majority and who needs further support. Guthrie v. Guthrie, 2015 Ark. App. 108, 455 S.W.3d 839 (2015).

Circuit court did not err by finding that a father's child support obligation did not automatically terminate at the age of majority due to the fact that the child at issue was a child with a disability. There was no error in addressing the issue at the time modification was sought because the child at issue was a child with a disability at the time he reached the age of majority and still resided with his mother at the time of the modification attempt. Miller v. Ark. Office of Child Support Enforcement, 2015 Ark. App. 188, 458 S.W.3d 733 (2015).

Special Circumstances.

Where child had reached the age of majority and had finished one year as a student at the University of Arkansas, even though he played in the University Band and when he went on band trips had to pay a portion of the cost of room and board, and even though he had allergies and had to take allergy medicine, there was nevertheless no showing of special circumstances that would justify an order of support. Aikens v. Lee, 53 Ark. App. 1, 918 S.W.2d 204 (1996).

The chancellor erred in terminating child support on the ground that the child at issue should have graduated from high school by his 18th birthday where the child's graduation was delayed because both parties agreed that the child should repeat second grade; however, the termination of child support was nevertheless affirmed because the stipulations of the parties indicated that the child spent only 25 percent of his time in the custodial parent's home. Office of Child Support Enforcement v. Calbert, 70 Ark. App. 520, 20 S.W.3d 450 (2000).

Trial court erred in reinstating child support for the parties' daughter who was emancipated and had reached the age of majority where there was no medical evidence or testimony as to the extent of the daughter's alleged impairment following an automobile accident other than the personal opinions of the parties and their daughter. Rogers v. Rogers, 83 Ark. App. 206, 121 S.W.3d 510 (2003).

Except for personal items, all of the needs of the parties' adult son, who was an individual with an intellectual disability, were covered by his SSI check, including housing, utilities, food, transportation, or phone bills; also, his pharmacy bills were covered expenses. Furthermore, he had approximately $300 in earned income and a small amount left from his SSI check after his other expenses were paid to purchase personal items; thus, the son's move into a group home from his mother's home constituted a sufficient change in circumstances to warrant termination of the father's child-support obligation. Bagley v. Williamson, 101 Ark. App. 1, 269 S.W.3d 837 (2007).

Child support determinations were not moot even though both sons had since turned 18 as the determinations addressed back child support, and because the order provided for support until the youngest son either turned 18 or graduated from high school, whichever occurred later, and that son had not yet graduated from high school. Maxwell v. Maxwell, 2020 Ark. App. 23, 593 S.W.3d 499 (2020).

Termination of Support.

Because the duty to pay child support terminates by operation of law, the Arkansas Legislature did not intend that the notice provision of subdivision (b)(5)(A) of this section require mandatory or strict compliance; therefore, a trial court should have calculated a father's obligation based on the amount owed for two minor children after a third child turned 18. Ward v. Doss, 361 Ark. 153, 205 S.W.3d 767 (2005).

In a divorce case, the trial court did not err by ordering former husband to pay former wife $100 per month in alimony because the evidence showed that he had the ability to pay, he was not responsible for child support after the child's graduation from high school, and the child's college expenses were not considered; moreover, husband's arguments concerning wife's decision to move and her accountability for her financial situation were rejected. Kuchmas v. Kuchmas, 368 Ark. 43, 243 S.W.3d 270 (2006).

Because a minor child had died, a mother was unable to bring a child support action against a father under § 9-14-105(b) since the mother no longer had physical custody of the child; moreover, the father's obligation to support the child terminated upon her death under subdivision (a)(1)(B) [now (a)(1)(C)] of this section. Hardy v. Wilbourne, 370 Ark. 359, 259 S.W.3d 405 (2007), cert. denied, 552 U.S. 1183, 128 S. Ct. 1245, 170 L. Ed. 2d 65 (2008).

Where a default judgment was entered in paternity proceedings and the adjudicated father's support obligation was established in 1995, the Office of Child Support Enforcement instituted proceedings in 2005 to recover support arrearages, and the adjudicated father requested a paternity test, the circuit court erred in granting the father's motion because the motion was untimely. Section 9-10-115(e)(1)(A) allows an adjudicated father one paternity test during any time period in which he is required to pay child support and the father's child support obligation terminated under this section when the child reached the age of majority. State v. Perry, 2012 Ark. 106 (2012).

The period that the father was “required to pay child support” ended under this section when the child turned 18; likewise, the period of time in which the father could seek a paternity test also ended when the child turned 18. State v. Perry, 2012 Ark. 106 (2012).

Cited: Laroe v. Laroe, 48 Ark. App. 192, 893 S.W.2d 344 (1995).

Notes of Decisions
Cited in 26 cases (1 in the last 5 years), 1995–2021 · leading case: Ward v. Doss, 205 S.W.3d 767 (Ark. 2005).
Sort: Relevance Newest Treatment
Ward v. Doss, 205 S.W.3d 767 (Ark. 2005). · cites it 30× “l-2(b)(6) because this case involves a substantial question of law regarding the validity, construction, and interpretation of Ark. Code Ann. § 9-14-237 (Supp. 2003). Facts Shelby and Teresa Gail Ward (Teresa) were divorced on January 9, 1996.”
Guthrie v. Guthrie, 2015 Ark. App. 108 (Ark. Ct. App. 2015). · cites it 12× “Ark. Code Ann. § 9-14-237 (Supp. 2005). However, the duty to support a child does not cease at majority if the child is mentally or physically disabled in any way at majority and needs support.”
Hardy v. Wilbourne, 259 S.W.3d 405 (Ark. 2007). · cites it 6× “] Ark. Code Ann. § 9-14-237 (a)(l)(B)(iii) (Supp.”
Harris v. Harris, 107 S.W.3d 897 (Ark. Ct. App. 2003). · cites it 6× “Appellant argues that when his oldest child turned eighteen years old, a change of circumstance occurred by operation of law pursuant to Ark. Code Ann. § 9-14-237 (Repl. 2002) sufficient to warrant a modification of his child-support obligation.”
Miller v. Arkansas Off. of Child Support Enf't, 2015 Ark. App. 188 (Ark. Ct. App. 2015). · cites it 8× “Ark. Code Ann. § 9-14-237 (Supp. 2005). However, the duty to support a child does not cease at majority if the child is mentally or physically disabled in any way at majority and needs support.”
Mixon v. Mixon, 987 S.W.2d 284 (Ark. Ct. App. 1999). · cites it 11× “The appellee argues that the chancery court did not retroactively modify child support prior to the date he filed the motion to modify.”
Laroe v. Laroe, 893 S.W.2d 344 (Ark. Ct. App. 1995). · cites it 7× “Appellant argues that the chancellor erred in not applying Ark. Code Ann. § 9-14-237 to the facts of this case and in not finding appellee was barred by laches and the doctrine of unclean hands from seeking judgment.”
In re Phillips, 496 S.W.3d 769 (Tex. 2016). · cites it 2× “Ark. Code § 9-14-237(a)(1). . Id. § 9-14-233(a).”
Vice v. Vice, 2016 Ark. App. 504 (Ark. Ct. App. 2016). · cites it 2× “He claims that his obligation to support Julia terminated' by operation of law, pursuant to Arkansas Code Annotated section 9-14-237, |fiwhen she reached the age of majority, and that he should receive a credit for all payments he made thereafter.”
Rogers v. Rogers, 121 S.W.3d 510 (Ark. Ct. App. 2003). · cites it 4× “Arkansas Code Annotated section 9-14-237 (Repl.2002) provides that an obligor's duty to pay child support for a child shall automatically terminate by operation of law when the child reaches eighteen years of age or should have graduated from high school, whichever is later.”
Kuchmas v. Kuchmas, 243 S.W.3d 270 (Ark. 2006). · cites it 2× “Moreover, under Ark. Code Ann. § 9-14-237 (Repl. 2002), “[a]n obligor’s duty to pay child support for a child shall automatically terminate by operation of law when the child reaches eighteen years of age or should have graduated from high school, whichever is later.”
Bagley v. Williamson, 269 S.W.3d 837 (Ark. Ct. App. 2007). · cites it 2× “Ark. Code Ann. § 9-14-237 (Supp. 2005). However, the duty to support a child does not cease at majority if the child is mentally or physically disabled in any way at majority and needs support.”
Show all 26 citing cases →
— Ark. Code Ann. § 9-14-237(a)(1) — 4 cases
In re Phillips, 496 S.W.3d 769 (Tex. 2016). “Ark. Code § 9-14-237(a)(1). . Id. § 9-14-233(a).”
Baker v. Off. of Child Support Enf't, 2017 Ark. App. 173 (Ark. Ct. App. 2017).
John A. Little, III (Bankr. E.D. Ark. 2021).
Off. of Child Support Enf't v. Calbert, 20 S.W.3d 450 (Ark. Ct. App. 2000).
— Ark. Code Ann. § 9-14-237(a)(l) — 4 cases
In re Phillips, 496 S.W.3d 769 (Tex. 2016). “Ark. Code § 9-14-237(a)(1). . Id. § 9-14-233(a).”
Hardy v. Wilbourne, 259 S.W.3d 405 (Ark. 2007). “] Ark. Code Ann. § 9-14-237 (a)(l)(B)(iii) (Supp.”
Aikens v. Lee, 918 S.W.2d 204 (Ark. Ct. App. 1996).
Off. of Child Support Enf't v. Calbert, 20 S.W.3d 450 (Ark. Ct. App. 2000).
— Ark. Code Ann. § 9-14-237(a)(l)(A)(i) — 1 case
Gillison v. Gillison, 382 S.W.3d 795 (Ark. Ct. App. 2011).
— Ark. Code Ann. § 9-14-237(a)(l)(B)(iii) — 1 case
Hardy v. Wilbourne, 259 S.W.3d 405 (Ark. 2007). “] Ark. Code Ann. § 9-14-237 (a)(l)(B)(iii) (Supp.”
— Ark. Code Ann. § 9-14-237(b)(1) — 1 case
Laroe v. Laroe, 893 S.W.2d 344 (Ark. Ct. App. 1995). “Appellant argues that the chancellor erred in not applying Ark. Code Ann. § 9-14-237 to the facts of this case and in not finding appellee was barred by laches and the doctrine of unclean hands from seeking judgment.”
— Ark. Code Ann. § 9-14-237(b)(5)(A) — 1 case
Ward v. Doss, 205 S.W.3d 767 (Ark. 2005). “l-2(b)(6) because this case involves a substantial question of law regarding the validity, construction, and interpretation of Ark. Code Ann. § 9-14-237 (Supp. 2003). Facts Shelby and Teresa Gail Ward (Teresa) were divorced on January 9, 1996.”
— Ark. Code Ann. § 9-14-237(b)(l) — 1 case
James v. James, 914 S.W.2d 773 (Ark. Ct. App. 1996).
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