This report analyzes the California Court of Appeal case Helgestad v. Vargas, which addresses the issue of whether a non-custodial parent is entitled to credit for child support provided during a period of reconciliation and cohabitation following a paternity action. The court reversed the trial court's denial of credit, holding that equitable considerations should apply to paternity cases similarly to dissolution actions. The court reasoned that actual support provided, regardless of the custody arrangement, should be considered. The decision clarifies the application of "Jackson credits" in paternity cases involving reconciliation and emphasizes the importance of considering the child's best interests. The report examines relevant case law, including the Jackson line of cases, Gregory-McCann cases, and Davis and Wilson-Bodine reconciliation cases, as well as out-of-state precedents. It distinguishes between different rationales for granting or denying credit, ultimately concluding that an equitable approach, allowing credit for actual support provided during cohabitation, best aligns with existing California law and public policy.
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