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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.
| Case | Followed | Cited |
|---|---|---|
Richardson v. Richardsongreen2 sentences2025Assignment 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)). | 9 | 11 |
Watkinson v. Henleygreen2 sentences2019Niblett 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). | 8 | 11 |
Amanda Swanson Niblett v. Jason Daniel Niblettgreen2 sentences2024“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 | 2 | 4 |
Farley v. Liskeygreen2 sentences2019Niblett 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). | 2 | 3 |
Drew Tidwell v. Jennifer Lategreen2 sentences2025Assignment 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)). | 2 | 2 |
Brody v. Brodygreen2 sentences2019Niblett 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). | 2 | 2 |
Michael A. Oley v. Lisa S. Branchgreen2 sentences2025Calculating 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)). | 1 | 3 |
O'BRIEN v. Rosegreen1 sentence2019Niblett 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 | 1 | 1 |
West v. Westgreen2 sentences2017“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)). | 1 | 1 |
Slonka v. Pennlinegreen2 sentences2008The 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). | 1 | 1 |
Scott v. Scottgreen2 sentences1999However, “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. | 1 | 1 |
Head v. Headgreen2 sentences1998DEVIATION 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). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sufian Da'mes v. Gada Da'mes
green
1 sentence2025Calculating 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)). | 1 | 2025–2025 |
Milligan v. Milligan
green
1 sentence1991Conway, 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. | 1 | 1991–1991 |
Conway v. Conway
green
1 sentence1991Conway, 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. | 1 | 1991–1991 |
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.