Vt. Stat. Ann. » Title 15 Chapter 11
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 651 (2026)

Repealed. 1985, No. 180 (Adj. Sess.), § 14, eff. April 1, 1987.

✓ current as of May 2026
Find cases: SyfertCases citing this section VT-LEGlegislature.vermont.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

Subchapter 003A : CHILD CUSTODY AND SUPPORT

(Cite as: 15 V.S.A. § 651)
Notes of Decisions
Cited in 12 cases, 1983–2001 · leading case: Lalumiere v. Lalumiere, 544 A.2d 1170 (Vt. 1988).
Sort: Relevance Newest Treatment
Lalumiere v. Lalumiere, 544 A.2d 1170 (Vt. 1988). · cites it 3× “The record reflects that defendant just barely had the *473 personal resources to care for herself; thus, we cannot say that the court abused its discretion under 15 V.”
Peckham v. Peckham, 543 A.2d 267 (Vt. 1988). · cites it 3× “Under 15 V.S.A. § 651 (Supp. 1984), 2 the trial court may order support when a request is made by a parent, guardian, custodian, the department of social and rehabilitation services, or by its own motion.”
McCormick v. McCormick, 553 A.2d 1098 (Vt. 1988). · cites it 2× “15 V.S.A. § 651(c). 4 This amount is calculated combining the -parties’ income for 1985, making the appropriate deductions, selecting the total guideline support amount from the table and allocating it to the parties in relation to their income.”
Viskup v. Viskup, 539 A.2d 554 (Vt. 1987). · cites it 2× “According to 15 V.S.A. § 651(e), 3 in order to modify a child support order there must be a showing of real, substantial and unanticipated change in circumstances.”
Roya v. Roya, 494 A.2d 132 (Vt. 1985). · cites it 2× “The provisions at issue in' the instant case, which adjust the amount of child support and spousal maintenance payments each year based on “the preceding year’s fluctuation in the cost of living,” are clearly a means of providing for variations in the cost of living due to…”
Lyon v. Lyon, 466 A.2d 1186 (Vt. 1983). · cites it 2× “Under 15 V.S.A. § 651 such payments are made for the support, maintenance and education of the minor children of the parties.”
Osborn v. Osborn, 519 A.2d 1161 (Vt. 1986). “Plaintiff also contends that once ordered under 15 V.S.A. § 651(d), support must continue until the later date of the child’s eighteenth birthday or the termination of secondary education.”
Forte v. Forte, 468 A.2d 561 (Vt. 1983). · cites it 2× “Thus, the superior court’s order on defendant’s motion, by first failing to state the actual amount of arrearage owing under the 1969 decree and then ordering plaintiff to pay an arrearage amount of $6,000.00, was not supported in law or fact and cannot stand.”
Cleverly v. Cleverly, 513 A.2d 612 (Vt. 1986). “2d 1192, 1192-93 (1985), that case involved a child support order issued prior to the enactment of 15 V.S.A. § 651. Section 651 refers exclusively to “the child.”
Sylvia v. Sylvia, 508 A.2d 708 (Vt. 1986). · cites it 2× “§§ 651(e) & 758 and, in the alternative, that the court’s award was not supported by its findings.”
Philburt v. Philburt, 533 A.2d 1181 (Vt. 1987). “Defendant’s brief does not cite the statutory provision controlling child support, 15 V.S.A. § 651, nor did defendant expressly address the child support issue in his brief or at oral argument.”
Morancy v. Morancy, 800 A.2d 435 (Vt. 2001). “Shortly after the Messier decision, however, we questioned its continued viability in light of the Legislature’s enactment of 15 V.S.A. § 651(d) (since recodified as § 658(e)), which, we noted, “refers exclusively to ‘the child’ .”
Vt. Stat. Ann. tit. 15, § 651(c): 2 cases
McCormick v. McCormick, 553 A.2d 1098 (Vt. 1988). “15 V.S.A. § 651(c). 4 This amount is calculated combining the -parties’ income for 1985, making the appropriate deductions, selecting the total guideline support amount from the table and allocating it to the parties in relation to their income.”
Roya v. Roya, 494 A.2d 132 (Vt. 1985). “The provisions at issue in' the instant case, which adjust the amount of child support and spousal maintenance payments each year based on “the preceding year’s fluctuation in the cost of living,” are clearly a means of providing for variations in the cost of living due to…”
Vt. Stat. Ann. tit. 15, § 651(d): 2 cases
Osborn v. Osborn, 519 A.2d 1161 (Vt. 1986). “Plaintiff also contends that once ordered under 15 V.S.A. § 651(d), support must continue until the later date of the child’s eighteenth birthday or the termination of secondary education.”
Morancy v. Morancy, 800 A.2d 435 (Vt. 2001). “Shortly after the Messier decision, however, we questioned its continued viability in light of the Legislature’s enactment of 15 V.S.A. § 651(d) (since recodified as § 658(e)), which, we noted, “refers exclusively to ‘the child’ .”
Vt. Stat. Ann. tit. 15, § 651(e): 3 cases
Viskup v. Viskup, 539 A.2d 554 (Vt. 1987). “According to 15 V.S.A. § 651(e), 3 in order to modify a child support order there must be a showing of real, substantial and unanticipated change in circumstances.”
McCormick v. McCormick, 553 A.2d 1098 (Vt. 1988). “15 V.S.A. § 651(c). 4 This amount is calculated combining the -parties’ income for 1985, making the appropriate deductions, selecting the total guideline support amount from the table and allocating it to the parties in relation to their income.”
Sylvia v. Sylvia, 508 A.2d 708 (Vt. 1986). “§§ 651(e) & 758 and, in the alternative, that the court’s award was not supported by its findings.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.