section 20-108.2(b) using the schedule found (Virginia) · Go Syfert
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section 20-108.2(b) using the schedule found in Virginia

26 Virginia opinions name it 3 courts 1991–2025 4 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
Richardson v. Richardsongreen
vactapp · 1991 · cited in 11 Virginia opinions naming this issue, 1991–2025
2 sentences

2025Assignment of Error 7 is general, stating that the court’s finding on McLawhorn’s income and amount of child support was plainly wrong and an abuse of discretion. -7- ANALYSIS A. Reasonable Business Expenses “The starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2.” Tidwell v. Late, 67 Va. App. 668, 679 (2017) (quoting Richardson v. Richardson, 12 Va. App. 18, 21 (1991)).

2024“The starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2.” Tidwell v. Late, 67 Va. App. 668, 679 (2017) (quoting Richardson v. Richardson, 12 Va. App. 18, 21 (1991)).

911
Watkinson v. Henleygreen
vactapp · 1991 · cited in 11 Virginia opinions naming this issue, 1992–2019
2 sentences

2019Niblett v. Niblett, 65 Va. App. 616, 625 (2015); Brody, 16 Va. App. at 650 (“Before imputing income to a party, the trial court must first determine the presumptive amount of child support under the guidelines.”); O’Brien v. Rose, 14 Va. App. 960, 963-64 (1992); Watkinson v. Henley, 13 Va. App. 151, 158 (1991) (“The starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).”); Farley v. Liskey, 12 Va. App. 1, 5 (1991) (“Imputed income is a fact

2013See Watkinson v. Henley, 13 Va. App. 151 , 409 S.E.2d 470 (1991) (the starting point for determining the child support obligation of a party is to compute the presumptive amount using the schedule found in Code § 20-108.2(B)); see also Farley v. Liskey, 12 Va. App. 1 , 401 S.E.2d 897 (1991) (stating that before any of the factors of Code § 20-108.1 can be considered, a trial court must first apply the child support guidelines of this section to determine the presumptively correct amount of child support).

811
Amanda Swanson Niblett v. Jason Daniel Niblettgreen
vactapp · 2015 · cited in 4 Virginia opinions naming this issue, 2017–2024
2 sentences

2024“The amount of child support under the child support guidelines must be based on the parents’ actual gross income.” Id. (quoting Niblett, 65 Va. App. at 625 ).

2019Niblett v. Niblett, 65 Va. App. 616, 625 (2015); Brody, 16 Va. App. at 650 (“Before imputing income to a party, the trial court must first determine the presumptive amount of child support under the guidelines.”); O’Brien v. Rose, 14 Va. App. 960, 963-64 (1992); Watkinson v. Henley, 13 Va. App. 151, 158 (1991) (“The starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).”); Farley v. Liskey, 12 Va. App. 1, 5 (1991) (“Imputed income is a fact

24
Farley v. Liskeygreen
vactapp · 1991 · cited in 3 Virginia opinions naming this issue, 1994–2019
2 sentences

2019Niblett v. Niblett, 65 Va. App. 616, 625 (2015); Brody, 16 Va. App. at 650 (“Before imputing income to a party, the trial court must first determine the presumptive amount of child support under the guidelines.”); O’Brien v. Rose, 14 Va. App. 960, 963-64 (1992); Watkinson v. Henley, 13 Va. App. 151, 158 (1991) (“The starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).”); Farley v. Liskey, 12 Va. App. 1, 5 (1991) (“Imputed income is a fact

2013See Watkinson v. Henley, 13 Va. App. 151 , 409 S.E.2d 470 (1991) (the starting point for determining the child support obligation of a party is to compute the presumptive amount using the schedule found in Code § 20-108.2(B)); see also Farley v. Liskey, 12 Va. App. 1 , 401 S.E.2d 897 (1991) (stating that before any of the factors of Code § 20-108.1 can be considered, a trial court must first apply the child support guidelines of this section to determine the presumptively correct amount of child support).

23
Drew Tidwell v. Jennifer Lategreen
vactapp · 2017 · cited in 2 Virginia opinions naming this issue, 2024–2025
2 sentences

2025Assignment of Error 7 is general, stating that the court’s finding on McLawhorn’s income and amount of child support was plainly wrong and an abuse of discretion. -7- ANALYSIS A. Reasonable Business Expenses “The starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2.” Tidwell v. Late, 67 Va. App. 668, 679 (2017) (quoting Richardson v. Richardson, 12 Va. App. 18, 21 (1991)).

2024“The starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2.” Tidwell v. Late, 67 Va. App. 668, 679 (2017) (quoting Richardson v. Richardson, 12 Va. App. 18, 21 (1991)).

22
Brody v. Brodygreen
vactapp · 1993 · cited in 2 Virginia opinions naming this issue, 1999–2019
2 sentences

2019Niblett v. Niblett, 65 Va. App. 616, 625 (2015); Brody, 16 Va. App. at 650 (“Before imputing income to a party, the trial court must first determine the presumptive amount of child support under the guidelines.”); O’Brien v. Rose, 14 Va. App. 960, 963-64 (1992); Watkinson v. Henley, 13 Va. App. 151, 158 (1991) (“The starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).”); Farley v. Liskey, 12 Va. App. 1, 5 (1991) (“Imputed income is a fact

1999Child Support "The starting point for determination of each parent's child support obligation is the amount calculated using the schedule found in Code § 20-108.2(B); however, that amount is subject to adjustment based on the factors found in Code § 20-108.1." Brody v. Brody, 16 Va. App. 647, 650 , 432 S.E.2d 20, 21 (1993).

22
Michael A. Oley v. Lisa S. Branchgreen
vactapp · 2014 · cited in 3 Virginia opinions naming this issue, 2015–2025
2 sentences

2025Calculating Child Support This Court has long recognized that the “starting point for a [circuit] court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2.” Da’mes, 74 Va. App. at 145 (quoting Oley v. Branch, 63 Va. App. 681, 689 (2014)).

2022Inheritance as Income Father’s first four assignments of error challenge the court’s ruling that his $600,000 inheritance constituted income for purposes of computing his monthly child support obligation. “[T]he starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2(B).” Oley, 63 Va. App. at 689 (quoting Richardson v. Richardson, 12 Va. App. 18, 21 (1991)).

13
O'BRIEN v. Rosegreen
vactapp · 1992 · cited in 1 Virginia opinions naming this issue, 2019–2019
1 sentence

2019Niblett v. Niblett, 65 Va. App. 616, 625 (2015); Brody, 16 Va. App. at 650 (“Before imputing income to a party, the trial court must first determine the presumptive amount of child support under the guidelines.”); O’Brien v. Rose, 14 Va. App. 960, 963-64 (1992); Watkinson v. Henley, 13 Va. App. 151, 158 (1991) (“The starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).”); Farley v. Liskey, 12 Va. App. 1, 5 (1991) (“Imputed income is a fact

11
West v. Westgreen
vactapp · 2008 · cited in 1 Virginia opinions naming this issue, 2017–2017
2 sentences

2017“The amount of child support under the child support guidelines must be based on the parents’ actual gross income.” Niblett, 65 Va.App. at 625 , 779 S.E.2d at 843 (quoting West v. West, 53 Va.App. 125, 135 , 669 S.E.2d 390, 395 (2008)).

2017“The amount of child support under the child support guidelines must be based on the parents’ actual gross income.” Niblett, 65 Va.App. at 625 , 779 S.E.2d at 843 (quoting West v. West, 53 Va.App. 125, 135 , 669 S.E.2d 390, 395 (2008)).

11
Slonka v. Pennlinegreen
vactapp · 1994 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008The child support order also does not explain the deviation. 2 As we explained in Slaonka v. Pennline, 17 Va. App. 662, 665 , 440 S.E.2d 423, 425 (1994) (citation and internal quotation marks omitted): It is well settled that the starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).

2008The child support order also does not explain the deviation. 2 As we explained in Slaonka v. Pennline, 17 Va. App. 662, 665 , 440 S.E.2d 423, 425 (1994) (citation and internal quotation marks omitted): It is well settled that the starting point . . . for determining the child support obligation of a party, whether initially or at a modification hearing, is to compute the presumptive amount using the schedule found in Code § 20-108.2(B).

11
Scott v. Scottgreen
vactapp · 1991 · cited in 1 Virginia opinions naming this issue, 1999–1999
2 sentences

1999However, “a trial court need not award child support in the statutorily presumptive amount if a deviation from such an amount is justified.” Scott v. Scott, 12 Va. App. 1245, 1249 , 408 S.E.2d 579, 582 (1991); see Code §§ 20-108.1, -108.2.

1999However, “a trial court need not award child support in the statutorily presumptive amount if a deviation from such an amount is justified.” Scott v. Scott, 12 Va. App. 1245, 1249 , 408 S.E.2d 579, 582 (1991); see Code §§ 20-108.1, -108.2.

11
Head v. Headgreen
vactapp · 1997 · cited in 1 Virginia opinions naming this issue, 1998–1998
2 sentences

1998DEVIATION FROM THE PRESUMPTIVELY CORRECT AMOUNT OF CHILD SUPPORT When determining a party's child support obligation at a modification hearing, "the court must begin by computing the * Pursuant to Code § 17-116.010 this opinion is not designated for publication. presumptive amount using the schedule found in Code § 20-108.2(B)." Head v. Head, 24 Va. App. 166, 178 , 480 S.E.2d 780, 786 (1997).

1998DEVIATION FROM THE PRESUMPTIVELY CORRECT AMOUNT OF CHILD SUPPORT When determining a party's child support obligation at a modification hearing, "the court must begin by computing the * Pursuant to Code § 17-116.010 this opinion is not designated for publication. presumptive amount using the schedule found in Code § 20-108.2(B)." Head v. Head, 24 Va. App. 166, 178 , 480 S.E.2d 780, 786 (1997).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Sufian Da'mes v. Gada Da'mes green
vactapp · 2022
1 sentence

2025Calculating Child Support This Court has long recognized that the “starting point for a [circuit] court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Code § 20-108.2.” Da’mes, 74 Va. App. at 145 (quoting Oley v. Branch, 63 Va. App. 681, 689 (2014)).

12025–2025
Milligan v. Milligan green
vactapp · 1991
1 sentence

1991Conway, supra, and the two recent cases of Richardson v. Richardson, 12 Va. App. 18 (1991), and Milligan v. Milligan, 12 Va. App. —, 407 S.E.2d 702 (1991), provide that the "starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Va. Code Section 20-108.2(B)." 12 Va. App. at 21.

11991–1991
Conway v. Conway green
vactapp · 1990
1 sentence

1991Conway, supra, and the two recent cases of Richardson v. Richardson, 12 Va. App. 18 (1991), and Milligan v. Milligan, 12 Va. App. —, 407 S.E.2d 702 (1991), provide that the "starting point for a trial court in determining the monthly child support obligation of a party is the amount as computed by the schedule found in Va. Code Section 20-108.2(B)." 12 Va. App. at 21.

11991–1991

Statutes the citing opinions construe

VA § Va. Code Ann. § 20-108.2 (26) VA § Va. Code Ann. § 20-108.1 (23) VA § Va. Code Ann. § 17.1-413 (10) VA § Va. Code Ann. § 20-107.2 (8) VA § Va. Code Ann. § 20-108 (7) VA § Va. Code Ann. § 20-107.3 (4) VA § Va. Code Ann. § 20-107.1 (3) VA § Va. Code Ann. § 20-109.1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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