Vermont Statutes Annotated

Vt. Stat. Ann. tit. 15, § 659 (2026)

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

(Cite as: 15 V.S.A. § 659)
Notes of Decisions
Cited in 30 cases (2 in the last 5 years), 1989–2026 · leading case: LaMothe v. LeBlanc, 2013 VT 21 (Vt. 2013).
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LaMothe v. LeBlanc, 2013 VT 21 (Vt. 2013). · cites it 9× “The suggestion that even if the magistrate’s initial guidelines calculation was substantially wrong, its purported decision to deviate insulates that calculation from review is puzzling. The guidelines calculation is presumed to reflect the amount of child support needed, 15 V.”
Ainsworth v. Ainsworth, 574 A.2d 772 (Vt. 1990). · cites it 8× “As discussed below, the trial court did not give detailed reasons for its conclusion or discuss the factors set forth in 15 V.S.A. § 659 for establishing a support order where it found an order based on the guidelines would be inequitable.”
Adamson v. Dodge, 816 A.2d 455 (Vt. 2002). · cites it 3× “He claims that the court may award support that is not based on the support guidelines only after consideration of the factors established in 15 V.S.A. § 659(a) and must *317 give an explanation of why these factors justify the deviation from the guidelines.”
Harris v. Harris, 714 A.2d 626 (Vt. 1998). · cites it 4× “Here, the magistrate considered mother's income as required, see 15 V.S.A. § 659(a)(2) (financial resources of custodial parent), and determined that the children were receiving a fair share of her income because she is the custodial parent and is maintaining a home for them.”
Tetreault v. Coon, 708 A.2d 571 (Vt. 1998). · cites it 4× “In response to the motion, father requested that the magistrate deviate from the child-support guidelines pursuant to 15 V.S.A. § 659(a) and set a support amount lower than the guidelines would require.”
Hunt v. Hunt, 648 A.2d 843 (Vt. 1994). · cites it 2× “15 V.S.A. § 659(a) (1989) (emphasis added).”
Smith v. Stewart, 684 A.2d 265 (Vt. 1996). · cites it 2× “§ 656(d), the family court had discretion to consider an award above the maximum guideline amount based on the factors in 15 V.S.A. § 659(a). See C.D., 160 Vt. at 500 , 631 A.”
Drummond v. State, 714 A.2d 163 (Md. 1998). “123(b)(3) (West 1996); Vt. Stat. Ann. tit. 15, § 659 (a)(1) (1989 & 1997 Supp.”
Milligan v. Milligan, 613 A.2d 1281 (Vt. 1992). “” The court found its authority to order a post-majority education allotment in 15 V.S.A. § 659(b), which provides that “[i]f the parties agree, the court may include in the child support order an additional amount designated for the purpose of providing for postsecondary…”
Grimes v. Grimes, 621 A.2d 211 (Vt. 1992). “” 15 V.S.A. § 659(a) (current version of the statute substitutes the term “unfair” for “inequitable”); Ainsworth v.”
Coyle v. Coyle, 2007 VT 21 (Vt. 2007). “NOTES [*] Mother argues that the family court's decision was not based on a jurisdictional question at all but rather on considerations of fairness to the children and parties under 15 V.S.A. § 659. Mother's contention is based on the court's summarizing statement that the…”
Guilford Cnty. Ex Rel. Easter v. Easter, 473 S.E.2d 6 (N.C. 1996). “055 (West 1994); Vt. Stat. Ann. tit. 15, § 659 (a) (Supp. 1993).”
Show all 30 citing cases →
— Vt. Stat. Ann. tit. 15, § 659(a) — 18 cases
Adamson v. Dodge, 816 A.2d 455 (Vt. 2002). “He claims that the court may award support that is not based on the support guidelines only after consideration of the factors established in 15 V.S.A. § 659(a) and must *317 give an explanation of why these factors justify the deviation from the guidelines.”
Tetreault v. Coon, 708 A.2d 571 (Vt. 1998). “In response to the motion, father requested that the magistrate deviate from the child-support guidelines pursuant to 15 V.S.A. § 659(a) and set a support amount lower than the guidelines would require.”
LaMothe v. LeBlanc, 2013 VT 21 (Vt. 2013). “The suggestion that even if the magistrate’s initial guidelines calculation was substantially wrong, its purported decision to deviate insulates that calculation from review is puzzling. The guidelines calculation is presumed to reflect the amount of child support needed, 15 V.”
Hunt v. Hunt, 648 A.2d 843 (Vt. 1994). “15 V.S.A. § 659(a) (1989) (emphasis added).”
Ainsworth v. Ainsworth, 574 A.2d 772 (Vt. 1990). “As discussed below, the trial court did not give detailed reasons for its conclusion or discuss the factors set forth in 15 V.S.A. § 659 for establishing a support order where it found an order based on the guidelines would be inequitable.”
— Vt. Stat. Ann. tit. 15, § 659(a)(1) — 1 case
Ainsworth v. Ainsworth, 574 A.2d 772 (Vt. 1990). “As discussed below, the trial court did not give detailed reasons for its conclusion or discuss the factors set forth in 15 V.S.A. § 659 for establishing a support order where it found an order based on the guidelines would be inequitable.”
— Vt. Stat. Ann. tit. 15, § 659(a)(10) — 1 case
Russell Japikse v. Jenny Parker (Vt. 2026).
— Vt. Stat. Ann. tit. 15, § 659(a)(2) — 2 cases
Harris v. Harris, 714 A.2d 626 (Vt. 1998). “Here, the magistrate considered mother's income as required, see 15 V.S.A. § 659(a)(2) (financial resources of custodial parent), and determined that the children were receiving a fair share of her income because she is the custodial parent and is maintaining a home for them.”
Catherine Hutchings v. Justin Bramhall (Vt. 2025).
— Vt. Stat. Ann. tit. 15, § 659(a)(3) — 1 case
Catherine Hutchings v. Justin Bramhall (Vt. 2025).
— Vt. Stat. Ann. tit. 15, § 659(a)(6) — 1 case
Adamson v. Dodge, 816 A.2d 455 (Vt. 2002). “He claims that the court may award support that is not based on the support guidelines only after consideration of the factors established in 15 V.S.A. § 659(a) and must *317 give an explanation of why these factors justify the deviation from the guidelines.”
— Vt. Stat. Ann. tit. 15, § 659(a)(7) — 1 case
Clayton v. Clayton, 569 A.2d 1077 (Vt. 1989).
— Vt. Stat. Ann. tit. 15, § 659(a)(l) — 1 case
Ainsworth v. Ainsworth, 574 A.2d 772 (Vt. 1990). “As discussed below, the trial court did not give detailed reasons for its conclusion or discuss the factors set forth in 15 V.S.A. § 659 for establishing a support order where it found an order based on the guidelines would be inequitable.”
— Vt. Stat. Ann. tit. 15, § 659(b) — 2 cases
Milligan v. Milligan, 613 A.2d 1281 (Vt. 1992). “” The court found its authority to order a post-majority education allotment in 15 V.S.A. § 659(b), which provides that “[i]f the parties agree, the court may include in the child support order an additional amount designated for the purpose of providing for postsecondary…”
Gerald R. Theberge v. Mary Ann R. Theberge, 2020 VT 13 (Vt. 2020).
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