Freeman remains precedent in “above-the-guidelines” cases.
Smith v. Freeman, 149 Md. App. 1 (2002).
In Smith, the Court of Special Appeals addressed another above-the-guidelines case. This case differs from the aforementioned cases as the parties were never married. Antonio Freeman, the appellee was a professional football player earning annual salaries over $1,000,000 per year. At all points relevant to this matter, the appellant was unemployed and attending school. When the parties initially entered into an agreement regarding child support, Mr. Freeman was making an annual salary of $1.2 million. At that time, Mr. Freeman was making a combined monthly child support payment of $4,016.66, which included the $3,500 child support payment the parties agreed upon and a monthly payment of $516.66 for the child’s tuition. Two years later, Mr. Freeman was making an annual salary of $3.2 million. Following this rise in salary, the appellant, Ms. Smith, requested a modification of the child support obligation arguing a material change in circumstances.