Virginia Code

Va. Code Ann. § 20-112 (2026)

Notice when proceedings reopened

✓ current as of May 2026

Find cases: SyfertCases citing this section VA-LISlaw.lis.virginia.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

When the proceedings are reopened to increase, decrease or terminate maintenance and support for a spouse or for a child, or to request additional orders to effectuate previous orders entered pursuant to § 20-107.3, the petitioning party shall give such notice to the other party by service of process or by order of publication as is required by law. Except as provided by § 20-110, no support order may be retroactively modified, but may be modified with respect to any period during which there is a pending petition for modification in any court, but only from the date that notice of such petition has been given to the responding party.

Code 1919, § 5111; 1944, p. 397; 1948, p. 593; 1975, c. 644; 1987, c. 649; 1991, c. 698; 2000, c. 221; 2004, c. 204.

Notes of Decisions

Cited in 36 cases (3 in the last 5 years), 1982–2025 · leading case: Reid v. Reid, 429 S.E.2d 208 (Va. 1993).

Sort: Relevance Newest Treatment

Reid v. Reid, 429 S.E.2d 208 (Va. 1993). · cites it 6× “” Code § 20-112. These provisions are of no aid to a party *413 seeking restitution for spousal support paid pursuant to an order later reversed.”

Schoenwetter v. Schoenwetter, 383 S.E.2d 28 (Va. Ct. App. 1989). · cites it 2× “Instead, the wife could have simply filed a petition for this purpose pursuant to Code § 20-112.”

Reid v. Reid, 409 S.E.2d 155 (Va. Ct. App. 1991). · cites it 8× “In conjunction with Code § 20-109, Code § 20-112 provides for notice to the responding spouse of the proceedings to increase, decrease or terminate spousal support, and specifically provides, in pertinent part, that “[n]o support order may be retroactively modified, but may be…”

Commonwealth Ex Rel. Comptroller of Virginia v. Skeens, 442 S.E.2d 432 (Va. Ct. App. 1994). · cites it 2× “2d 663, 666-67 (1965); Code § 20-112. Generally, the terms of a support decree must be strictly complied with and payments made when due to the designated payee in accordance with the terms of the decree.”

Carter v. Thornhill, 453 S.E.2d 295 (Va. Ct. App. 1995). · cites it 2× “3 The statute in effect at the time, California Civil Code § 4700, was similar to Virginia Code § 20-112 and stated in pertinent part: Any order for child support may be modified or revoked as the court may deem necessary, except as to any amount that may have accrued prior to…”

Peter Weidlein v. Mimi C. Weidlein, 777 S.E.2d 222 (Va. Ct. App. 2015). · cites it 8× “3 When a trial court honors the parties’ agreement, as it must, such a judgment does not retroactively modify a support award, in contravention of Code § 20-112. Instead, it enforces a pre-existing award according to its plain terms.”

Reid v. Reid, 419 S.E.2d 398 (Va. Ct. App. 1992). · cites it 6× “In conjunction with Code § 20-109, Code § 20-112 provides for notice to the responding spouse of the proceeding to increase, decrease or terminate spousal support, and specifically provides, in pertinent part, that “[n]o support order may be retroactively modified, but may be…”

Steven Lamont Forte v. Commonwealth of Virginia, 772 S.E.2d 303 (Va. Ct. App. 2015). · cites it 2× “See Code § 20-112 (“[w]hen proceedings are reopened to increase, decrease or terminate maintenance and support for a spouse or for a child” (emphasis added)).”

Kaminsky v. Kaminsky, 60 Va. Cir. 353 (2002). · cites it 6× “2d 432 (1994); Va. Code § 20-112. Recently, the Court of Appeals of Virginia in Shoup v.”

Julia Snell v. Thomas Davis (Va. Ct. App. 2021). · cites it 12× “However, in relevant part, Reid also stated the following regarding Code § 20-112, which governs reopened proceedings in a divorce case: The General Assembly did not ignore the possibility of altering spousal support awards retroactively, which would effectively occur if…”

Everett v. Tawes (Va. 2019). · cites it 10× “8 Code § 20-112 states, in relevant part: When the proceedings are reopened to increase, decrease or terminate maintenance and support for a spouse .”

Reid v. Reid, 409 S.E.2d 155 (Va. Ct. App. 1991). · cites it 8× “In conjunction with Code § 20-109, Code § 20-112 provides for notice to the responding spouse of the proceedings to increase, decrease or terminate spousal support, and specifically provides, in pertinent part, that "[n]o support order may be retroactively modified, but may be…”

Show all 36 citing cases →

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.