Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 656 (2026)

✓ current as of May 2026
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Subchapter 003A : CHILD CUSTODY AND SUPPORT

(Cite as: 15 V.S.A. § 656)
Notes of Decisions
Cited in 24 cases (2 in the last 5 years), 1987–2026 · leading case: Harris v. Harris, 714 A.2d 626 (Vt. 1998).
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Harris v. Harris, 714 A.2d 626 (Vt. 1998). · cites it 15× “Father next argues that, even if the magistrate has the discretion to fashion a child support order without extrapolating from the guidelines, she abused that discretion by (a) ordering child support that exceeds the needs of the children, (b) failing to divide the child support…”
Hunt v. Hunt, 648 A.2d 843 (Vt. 1994). · cites it 4× “See 15 V.S.A. § 656(b). Therefore, if the hearing officer erred in not exercising discretion to exclude the income described in § 653(5)(C), the error is harmless.”
LaMothe v. LeBlanc, 2013 VT 21 (Vt. 2013). · cites it 2× “” 15 V.S.A. § 656(a). The custodial parent is presumed to spend his or her share of the total support obligation directly on the child.”
Ainsworth v. Ainsworth, 574 A.2d 772 (Vt. 1990). · cites it 2× “§ 296, such a duty should not dilute his duty to pay child support to his natural children under 15 V.S.A. § 656(a). As I have emphasized, the guideline figure is based on the parties' gross incomes.”
Hannah P. Sachs v. Downs Rachlin Martin PLLC & Caryn Waxman, Esq., 179 A.3d 182 (Vt. 2017). “Thus, as a direct result of defendant's negligent advice to delay filing, plaintiff did not receive fifteen months of child support, from July 2011 to October 2012, nor could she retroactively recover the child support.”
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “See 15 V.S.A. § 656(a). We see no reason to deviate from this rule in this case.”
Debbie A. (Shattuck) Leitgeb v. Robert Leitgeb, 2016 VT 97 (Vt. 2016). · cites it 6× “15 V.S.A. § 656(b). However, with respect to arrearages, as opposed to ongoing support, the statute provides: If the noncustodial parent owes arrears to the custodial parent, the court shall not order the payment of arrears in an amount that, by itself or in combination with the…”
Adamson v. Dodge, 816 A.2d 455 (Vt. 2002). “15 V.S.A § 656(d). This discretion is not boundless, however.”
Cardiff v. Ellinwood, 2007 VT 88 (Vt. 2007). · cites it 2× “§ 650, which "declares as public policy that parents have the responsibility to provide child support and that child support orders should reflect the true costs of raising children and approximate insofar as possible the standard of living the child would have enjoyed had the…”
Smith v. Stewart, 684 A.2d 265 (Vt. 1996). · cites it 2× “” 15 V.S.A. § 656(d). Before addressing defendant’s specific argument, it is important to understand how the family court approached this case.”
Nevitt v. Nevitt, 584 A.2d 1134 (Vt. 1990). “§§ 657(a) and 659(a); however, we have no indication that the trial court used either of these bases since it offered no explanation for its act.”
Viskup v. Viskup, 522 A.2d 400 (Vt. 1988). “15 V.S.A. § 656(b). Thus, it is clear that the Legislature in enacting the new child support laws intended to require at least a nominal child support award in all cases.”
Show all 24 citing cases →
— Vt. Stat. Ann. tit. 15, § 656(a) — 9 cases
Harris v. Harris, 714 A.2d 626 (Vt. 1998). “Father next argues that, even if the magistrate has the discretion to fashion a child support order without extrapolating from the guidelines, she abused that discretion by (a) ordering child support that exceeds the needs of the children, (b) failing to divide the child support…”
LaMothe v. LeBlanc, 2013 VT 21 (Vt. 2013). “” 15 V.S.A. § 656(a). The custodial parent is presumed to spend his or her share of the total support obligation directly on the child.”
Ainsworth v. Ainsworth, 574 A.2d 772 (Vt. 1990). “§ 296, such a duty should not dilute his duty to pay child support to his natural children under 15 V.S.A. § 656(a). As I have emphasized, the guideline figure is based on the parties' gross incomes.”
Klein v. Klein, 555 A.2d 382 (Vt. 1988). “See 15 V.S.A. § 656(a). We see no reason to deviate from this rule in this case.”
Nevitt v. Nevitt, 584 A.2d 1134 (Vt. 1990). “§§ 657(a) and 659(a); however, we have no indication that the trial court used either of these bases since it offered no explanation for its act.”
— Vt. Stat. Ann. tit. 15, § 656(b) — 8 cases
Hunt v. Hunt, 648 A.2d 843 (Vt. 1994). “See 15 V.S.A. § 656(b). Therefore, if the hearing officer erred in not exercising discretion to exclude the income described in § 653(5)(C), the error is harmless.”
Hannah P. Sachs v. Downs Rachlin Martin PLLC & Caryn Waxman, Esq., 179 A.3d 182 (Vt. 2017). “Thus, as a direct result of defendant's negligent advice to delay filing, plaintiff did not receive fifteen months of child support, from July 2011 to October 2012, nor could she retroactively recover the child support.”
Cardiff v. Ellinwood, 2007 VT 88 (Vt. 2007). “§ 650, which "declares as public policy that parents have the responsibility to provide child support and that child support orders should reflect the true costs of raising children and approximate insofar as possible the standard of living the child would have enjoyed had the…”
Viskup v. Viskup, 522 A.2d 400 (Vt. 1988). “15 V.S.A. § 656(b). Thus, it is clear that the Legislature in enacting the new child support laws intended to require at least a nominal child support award in all cases.”
Debbie A. (Shattuck) Leitgeb v. Robert Leitgeb, 2016 VT 97 (Vt. 2016). “15 V.S.A. § 656(b). However, with respect to arrearages, as opposed to ongoing support, the statute provides: If the noncustodial parent owes arrears to the custodial parent, the court shall not order the payment of arrears in an amount that, by itself or in combination with the…”
— Vt. Stat. Ann. tit. 15, § 656(c) — 1 case
Debbie A. (Shattuck) Leitgeb v. Robert Leitgeb, 2016 VT 97 (Vt. 2016). “15 V.S.A. § 656(b). However, with respect to arrearages, as opposed to ongoing support, the statute provides: If the noncustodial parent owes arrears to the custodial parent, the court shall not order the payment of arrears in an amount that, by itself or in combination with the…”
— Vt. Stat. Ann. tit. 15, § 656(d) — 7 cases
Harris v. Harris, 714 A.2d 626 (Vt. 1998). “Father next argues that, even if the magistrate has the discretion to fashion a child support order without extrapolating from the guidelines, she abused that discretion by (a) ordering child support that exceeds the needs of the children, (b) failing to divide the child support…”
Adamson v. Dodge, 816 A.2d 455 (Vt. 2002). “15 V.S.A § 656(d). This discretion is not boundless, however.”
Smith v. Stewart, 684 A.2d 265 (Vt. 1996). “” 15 V.S.A. § 656(d). Before addressing defendant’s specific argument, it is important to understand how the family court approached this case.”
C.D. v. N.M., 631 A.2d 848 (Vt. 1993).
McCormick v. McCormick, 621 A.2d 238 (Vt. 1993).
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