The Missouri Court of Appeals for the Western District of Missouri has recently held that Incompletes, later completed with passing grades, count as college credit hours under statute determining continuation of child support obligation past the age of 18 years.

Generally, a parent's child support obligation terminates when the child reaches the age of eighteen. However, f when a child reaches eighteen, ... the child is enrolled in an institution of vocational or higher education not later than October first following graduation from a secondary school or completion of a graduation equivalence degree program and so long as the child enrolls for and completes at least twelve hours of credit each semester ... at an institution of vocational or higher education and achieves grades sufficient to re-enroll at such institution, the parental support obligation shall continue until the child completes his or her education, or until the child reaches the age of twenty-one (twenty-two before August 2008), whichever first occurs.

To remain eligible for such continued parental support, at the beginning of each semester the child shall submit to each parent a transcript or similar official document provided by the institution of vocational or higher education which includes the courses the child is enrolled in and has completed for each term, the grades and credits received for each such course, and an official document from the institution listing the courses which the child is enrolled in for the upcoming term and the number of credits for each such course.

A child who is employed at least fifteen hours per week during the semester may take as few as nine credit hours per semester and remain eligible for child support so long as all other requirements of this subsection are complied with.

In the recent case of Wilkerson v. Wilkerson, the college student had two "incomplete" grades when the term ended and, therefore, she actually completed only seven hours during that semester. However, she later completed the classes and received full credit for that particular semester, so the Court ruled that she met the statutory requirements completing the classes and the child support obligation continued. Note however that the case of Lombardo v. Lombardo held that that a student who had failed courses could not meet the statutory requirements by merely enrolling and attending classes.

The Court in Wilkerson apparently viewed incomplete grades as temporarily incomplete. However, there was no indication given as to how long a student would be given to complete the class, or when the child support would terminate in the event that the incomplete was not eventually completed.