New Jersey courts have long recognized a child’s need for higher education. In that regard, parents can be ordered by the Court to contribute toward the cost of their child’s higher education expenses. This obligation was officially established in the seminal case of Newburgh v. Arrigo, 88 N.J. 529 (1982). In Newburgh, the New Jersey Supreme Court explained that “the privilege of parenthood carries with it the duty to assure a necessary education for children.” Id. at 545. Necessary support for unemancipated children could include contribution toward the cost of a college education, even though the child has attained the age of majority.

The Court in Newburgh set forth the following twelve factors the courts should consider when evaluating a claim for contribution toward the cost of higher education:
 

1. Whether the parent, if still living with the child, would have contributed toward the costs of the requested higher education;
2. the effect of the background, values and goals of the parent on the reasonableness of the expectation of the child for higher education;
3. the amount of the contribution sought by the child for the cost of higher education;
4. the ability of the parent to pay that cost;
5. the relationship of the requested contribution to the kind of school or course of study sought by the child;
6. the financial resources of both parents;
7. the commitment to and aptitude of the child for the requested education;
8. the financial resources of the child, including assets owned individually or held in custodianship or trust;
9. the ability of the child to earn income during the school year or on vacation;
10. the availability of financial aid in the form of college grants and loans;
11. the child’s relationship to the paying parent, including mutual affection and shared goals as well as responsiveness to parental advice and guidance; and
12. the relationship of the education requested to any prior training and to the overall long-range goals of the child.