Revised Code of Washington

Wash. Rev. Code § 26.09.170 (2026)

✓ current as of May 2026

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(1) Except as otherwise provided in RCW 26.09.070(7), the provisions of any decree respecting maintenance or support may be modified: (a) Only as to installments accruing subsequent to the petition for modification or motion for adjustment except motions to compel court-ordered adjustments, which shall be effective as of the first date specified in the decree for implementing the adjustment; and, (b) except as otherwise provided in this section, only upon a showing of a substantial change of circumstances. The provisions as to property disposition may not be revoked or modified, unless the court finds the existence of conditions that justify the reopening of a judgment under the laws of this state.

(2) Unless otherwise agreed in writing or expressly provided in the decree the obligation to pay future maintenance is terminated upon the death of either party or the remarriage of the party receiving maintenance or registration of a new domestic partnership of the party receiving maintenance.

(3) Unless otherwise agreed in writing or expressly provided in the decree, provisions for the support of a child are terminated by emancipation of the child or by the death of the person required to pay support for the child.

(4) Unless expressly provided by an order of the superior court or a court of comparable jurisdiction, provisions for the support of a child are terminated upon the marriage or registration of a domestic partnership to each other of parties to a paternity or parentage order, or upon the remarriage or registration of a domestic partnership to each other of parties to a decree of dissolution. The remaining provisions of the order, including provisions establishing parentage, remain in effect.

(5)(a) A party to an order of child support may petition for a modification based upon a showing of substantially changed circumstances at any time.

(b) The voluntary unemployment or voluntary underemployment of the person required to pay support, by itself, is not a substantial change of circumstances.

(6) An order of child support may be modified at any time to add language regarding abatement to ten dollars per month per order due to the incarceration of the person required to pay support, as provided in RCW 26.09.320.

(a) The department of social and health services, the person entitled to receive support or the payee under the order, or the person required to pay support may petition for a prospective modification of a child support order if the person required to pay support is currently confined in a jail, prison, or correctional facility for at least six months or is serving a sentence greater than six months in a jail, prison, or correctional facility, and the support order does not contain language regarding abatement due to incarceration.

(b) The petition may only be filed if the person required to pay support is currently incarcerated.

(c) As part of the petition for modification, the petitioner may also request that the support obligation be abated to ten dollars per month per order due to incarceration, as provided in RCW 26.09.320.

(7) An order of child support may be modified without showing a substantial change of circumstances if the requested modification is to modify an existing order when the person required to pay support has been released from incarceration, as provided in RCW 26.09.320(3)(d).

(8) An order of child support may be modified one year or more after it has been entered without a showing of substantially changed circumstances:

(a) If the order in practice works a severe economic hardship on either party or the child;

(b) If a child is still in high school, upon a finding that there is a need to extend support beyond the eighteenth birthday to complete high school; or

(9)(a) If twenty-four months have passed from the date of the entry of the order or the last adjustment or modification, whichever is later, the order may be adjusted without a showing of substantially changed circumstances based upon:

(i) Changes in the income of the person required to pay support, or of the payee under the order or the person entitled to receive support who is a parent of the child or children covered by the order; or

(ii) Changes in the economic table or standards in chapter 26.19 RCW.

(b) Either party may initiate the adjustment by filing a motion and child support worksheets.

(c) If the court adjusts or modifies a child support obligation pursuant to this subsection by more than thirty percent and the change would cause significant hardship, the court may implement the change in two equal increments, one at the time of the entry of the order and the second six months from the entry of the order. Twenty-four months must pass following the second change before a motion for another adjustment under this subsection may be filed.

(10)(a) The department of social and health services may file an action to modify or adjust an order of child support if public assistance money is being paid to or for the benefit of the child and the department has determined that the child support order is at least fifteen percent above or below the appropriate child support amount set forth in the standard calculation as defined in RCW 26.19.011.

(b) The department of social and health services may file an action to modify or adjust an order of child support in a nonassistance case if:

(i) The department has determined that the child support order is at least fifteen percent above or below the appropriate child support amount set forth in the standard calculation as defined in RCW 26.19.011;

(ii) The department has determined the case meets the department's review criteria; and

(iii) A party to the order or another state or jurisdiction has requested a review.

(c) If incarceration of the person required to pay support is the basis for the difference between the existing child support order amount and the proposed amount of support determined as a result of a review, the department may file an action to modify or adjust an order of child support even if:

(i) There is no other change of circumstances; and

(ii) The change in support does not meet the fifteen percent threshold.

(d) The determination of whether the child support order is at least fifteen percent above or below the appropriate child support amount must be based on the current income of the parties.

(11) The department of social and health services may file an action to modify or adjust an order of child support under subsections (5) through (9) of this section if:

(a) Public assistance money is being paid to or for the benefit of the child;

(b) A party to the order in a nonassistance case has requested a review; or

(12) If testimony other than affidavit is required in any proceeding under this section, a court of this state shall permit a party or witness to be deposed or to testify under penalty of perjury by telephone, audiovisual means, or other electronic means, unless good cause is shown.

[ 2020 c 227 s 13; 2019 c 275 s 2; 2010 c 279 s 1; 2008 c 6 s 1017; 2002 c 199 s 1; 1997 c 58 s 910; 1992 c 229 s 2; 1991 sp.s. c 28 s 2; 1990 1st ex.s. c 2 s 2; 1989 c 416 s 3; 1988 c 275 s 17; 1987 c 430 s 1; 1973 1st ex.s. c 157 s 17.]

Notes:

Effective date—2020 c 227 ss 3-13: See note following RCW 26.09.320.

Findings—Intent—2020 c 227: See note following RCW 26.09.320.

Rule-making authority—2020 c 227: See RCW 26.09.916.

Part headings not law—Severability—2008 c 6: See RCW 26.60.900 and 26.60.901.

Short title—Part headings, captions, table of contents not law—Exemptions and waivers from federal law—Conflict with federal requirements—Severability—1997 c 58: See RCW 74.08A.900 through 74.08A.904.

Severability—Effective date—Captions not law—1991 sp.s. c 28: See notes following RCW 26.09.100.

Effective dates—Severability—1990 1st ex.s. c 2: See notes following RCW 26.09.100.

Effective dates—Severability—1988 c 275: See notes following RCW 26.19.001.

Severability—1987 c 430: "If any provision of this act or its application to any person or circumstance is held invalid, the remainder of the act or the application of the provision to other persons or circumstances is not affected." [ 1987 c 430 s 4.]

(5)(a) A party to an order of child support may petition for a modification based upon a showing of substantially changed circumstances at any time.

(b) The voluntary unemployment or voluntary underemployment of the person required to pay support, by itself, is not a substantial change of circumstances.

(6) An order of child support may be modified at any time to add language regarding abatement to $10 per month per order due to the incarceration of the person required to pay support, as provided in RCW 26.09.320, or abatement to $50 per month per child due to incapacitation of the person required to pay support, as provided in RCW 26.09.345.

(a) The department of social and health services, the person entitled to receive support or the payee under the order, or the person required to pay support may petition for a prospective modification of a child support order if: (i) The person required to pay support is currently confined in a jail, prison, or correctional facility for at least six months or is serving a sentence greater than six months in a jail, prison, or correctional facility, and the support order does not contain language regarding abatement due to incarceration; or (ii) the person required to pay support is currently undergoing court-ordered behavioral health treatment and the support order does not contain language regarding abatement due to incapacitation.

(b) The petition may only be filed if the person required to pay support is currently incarcerated or incapacitated.

(c) As part of the petition for modification, the petitioner may also request that the support obligation be abated to $10 per month per order due to incarceration, as provided in RCW 26.09.320, or abated to $50 per month per child due to incapacitation, as provided in RCW 26.09.345.

(7) An order of child support may be modified without showing a substantial change of circumstances if the requested modification is to: (a) Modify an existing order when the person required to pay support has been released from incarceration, as provided in RCW 26.09.320(3)(d); or (b) modify an existing order when the person required to pay support has been discharged from court-ordered behavioral health treatment, as provided in RCW 26.09.345.

(8) An order of child support may be modified one year or more after it has been entered without a showing of substantially changed circumstances:

(a) If the order in practice works a severe economic hardship on either party or the child;

(b) If a child is still in high school, upon a finding that there is a need to extend support beyond the eighteenth birthday to complete high school; or

(9)(a) If 24 months have passed from the date of the entry of the order or the last adjustment or modification, whichever is later, the order may be adjusted without a showing of substantially changed circumstances based upon:

(ii) Changes in the economic table or standards in chapter 26.19 RCW.

(b) Either party may initiate the adjustment by filing a motion and child support worksheets.

(c) If the court adjusts or modifies a child support obligation pursuant to this subsection by more than 30 percent and the change would cause significant hardship, the court may implement the change in two equal increments, one at the time of the entry of the order and the second six months from the entry of the order. Twenty-four months must pass following the second change before a motion for another adjustment under this subsection may be filed.

(10)(a) The department of social and health services may file an action to modify or adjust an order of child support if public assistance money is being paid to or for the benefit of the child and the department has determined that the child support order is at least 15 percent above or below the appropriate child support amount set forth in the standard calculation as defined in RCW 26.19.011.

(b) The department of social and health services may file an action to modify or adjust an order of child support in a nonassistance case if:

(i) The department has determined that the child support order is at least 15 percent above or below the appropriate child support amount set forth in the standard calculation as defined in RCW 26.19.011;

(ii) The department has determined the case meets the department's review criteria; and

(iii) A party to the order or another state or jurisdiction has requested a review.

(i) There is no other change of circumstances; and

(ii) The change in support does not meet the 15 percent threshold.

(d) The determination of whether the child support order is at least 15 percent above or below the appropriate child support amount must be based on the current income of the parties.

(11) The department of social and health services may file an action to modify or adjust an order of child support under subsections (5) through (9) of this section if:

(a) Public assistance money is being paid to or for the benefit of the child;

(b) A party to the order in a nonassistance case has requested a review; or

[ 2025 c 272 s 8; 2020 c 227 s 13; 2019 c 275 s 2; 2010 c 279 s 1; 2008 c 6 s 1017; 2002 c 199 s 1; 1997 c 58 s 910; 1992 c 229 s 2; 1991 sp.s. c 28 s 2; 1990 1st ex.s. c 2 s 2; 1989 c 416 s 3; 1988 c 275 s 17; 1987 c 430 s 1; 1973 1st ex.s. c 157 s 17.]

Notes:

Effective date—2025 c 272 ss 4-12: See note following RCW 26.09.345.

Rule-making authority—2025 c 272: See note following RCW 26.09.345.

Effective date—2020 c 227 ss 3-13: See note following RCW 26.09.320.

Findings—Intent—2020 c 227: See note following RCW 26.09.320.

Rule-making authority—2020 c 227: See RCW 26.09.916.

Part headings not law—Severability—2008 c 6: See RCW 26.60.900 and 26.60.901.

Severability—Effective date—Captions not law—1991 sp.s. c 28: See notes following RCW 26.09.100.

Effective dates—Severability—1990 1st ex.s. c 2: See notes following RCW 26.09.100.

Effective dates—Severability—1988 c 275: See notes following RCW 26.19.001.

Notes of Decisions

Cited in 261 cases (33 in the last 5 years), 1974–2026 · leading case: In re the Marriage of Scanlon, 109 Wash. App. 167 (Wash. Ct. App. 2001).

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In re the Marriage of Scanlon, 109 Wash. App. 167 (Wash. Ct. App. 2001). · cites it 11× “RCW 26.09.170 states in relevant part: (1) .”

In Re Marriage of Scanlon & Witrak, 34 P.3d 877 (Wash. Ct. App. 2001). · cites it 11× “RCW 26.09.170 states in relevant part: *882 (1) [T]he provisions of any decree respecting maintenance or support may be modified:.”

In Re the Marriage of Gimlett, 629 P.2d 450 (Wash. 1981). · cites it 9× “The Court of Appeals reversed the trial court, holding that "emancipation" as used in RCW 26.09.170 was not intended to be equated with "cessation of dependency".”

In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). · cites it 8× “Proper Procedure Is Petition To Modify ¶17 RCW 26.09.170 explains how and when a child support order can be modified.”

In Re the Marriage of Blickenstaff & Blickenstaff, 859 P.2d 646 (Wash. Ct. App. 1993). · cites it 11× “He contends the trial court erred in finding him to be voluntarily unemployed and in imputing income to him, which thereby prevented him from demonstrating the substantial change in circumstances necessary for a modification under RCW 26.09.170-(1), or the change of income…”

In re the Marriage of Drlik, 121 Wash. App. 269 (Wash. Ct. App. 2004). · cites it 7× “We hold that the trial court had authority under RCW 26.09.170 to suspend the maintenance obligation.”

In re the Marriage of Cota, 312 P.3d 695 (Wash. Ct. App. 2013). · cites it 6× “At issue here is whether the trial court had authority to order postsecondary educational support in light of RCW 26.09.170(3). See Major, 71 Wn. App. at 536 .”

In re the Marriage of Moody, 976 P.2d 1240 (Wash. 1999). · cites it 5× “Although the dissolution of marriage act creates an avenue for modifying spousal maintenance awards, RCW 26.09.170(1), Homer has not petitioned for modification under the statute.”

In Re Marriage of Moody, 976 P.2d 1240 (Wash. 1999). · cites it 5× “Although the dissolution of marriage act creates an avenue for modifying spousal maintenance awards, RCW 26.09.170(1), Homer has not petitioned for modification under the statute.”

In Re the Marriage of Washburn, 677 P.2d 152 (Wash. 1984). · cites it 4× “Additionally, RCW 26.09.170 authorizes the court to continue the maintenance obligation beyond the death of either party or the remarriage of the party receiving maintenance.”

In re the Marriage of Ayyad, 38 P.3d 1033 (Wash. Ct. App. 2002). · cites it 5× “3 Contrary to Rashid’s assertion, RCW 26.09.170-(l)(a) enforces automatic adjustments even when the parents’ combined income exceeds $7,000.”

In re the Marriage of Spreen, 107 Wash. App. 341 (Wash. Ct. App. 2001). · cites it 3× “” Thus, Marie is free to petition again for modification if she wishes, as long as she can demonstrate a change in circumstances as RCW 26.09.170 requires. II. Attorney Fees Although Marie devotes a section of her opening and reply briefs to attorney fees, it is unclear what she…”

Show all 261 citing cases →

— Wash. Rev. Code § 26.09.170(1) — 87 cases

In re the Marriage of Scanlon, 109 Wash. App. 167 (Wash. Ct. App. 2001). “RCW 26.09.170 states in relevant part: (1) .”

In Re Marriage of Scanlon & Witrak, 34 P.3d 877 (Wash. Ct. App. 2001). “RCW 26.09.170 states in relevant part: *882 (1) [T]he provisions of any decree respecting maintenance or support may be modified:.”

In re the Marriage of Moody, 976 P.2d 1240 (Wash. 1999). “Although the dissolution of marriage act creates an avenue for modifying spousal maintenance awards, RCW 26.09.170(1), Homer has not petitioned for modification under the statute.”

In Re Marriage of Moody, 976 P.2d 1240 (Wash. 1999). “Although the dissolution of marriage act creates an avenue for modifying spousal maintenance awards, RCW 26.09.170(1), Homer has not petitioned for modification under the statute.”

In Re the Marriage of Thompson, 988 P.2d 499 (Wash. Ct. App. 1999).

— Wash. Rev. Code § 26.09.170(1)(a) — 9 cases

In Re Marriage of Ayyad, 38 P.3d 1033 (Wash. Ct. App. 2002).

In Re Marriage of Drlik, 87 P.3d 1192 (Wash. Ct. App. 2004).

In Re Marriage of Kahle, 138 P.3d 1129 (Wash. Ct. App. 2006).

In re the Marriage of Olson, 999 P.2d 1286 (Wash. Ct. App. 2000).

Royal Fish, Sr., Appellant/cross-respondent v. Lisa Fish, Respondent/cross-appellant (Wash. Ct. App. 2017).

— Wash. Rev. Code § 26.09.170(1)(b) — 17 cases

Fox v. Fox, 942 P.2d 1084 (Wash. Ct. App. 1997).

Lila F. Scholl v. Lee W. Scholl (Wash. Ct. App. 2020).

In Re The Marriage Of: Zeleke Kassahun v. Fanaye Ashagari (Wash. Ct. App. 2017).

In Re: Marriage Of Jose Ocasio-santiago, App/cross-resp & Kimberley Ocasio, Resp/cross-app (Wash. Ct. App. 2017).

Royal Fish, Sr., Appellant/cross-respondent v. Lisa Fish, Respondent/cross-appellant (Wash. Ct. App. 2017).

— Wash. Rev. Code § 26.09.170(10) — 2 cases

In re the Marriage of Kahle, 134 Wash. App. 155 (Wash. Ct. App. 2006).

In Re Marriage of Kahle, 138 P.3d 1129 (Wash. Ct. App. 2006).

— Wash. Rev. Code § 26.09.170(2) — 16 cases

Moore v. Jacobsen, 817 A.2d 212 (Md. 2003).

In Re the Marriage of Williams, 796 P.2d 421 (Wash. 1990).

In the Matter of Marriage of Tower, 780 P.2d 863 (Wash. Ct. App. 1989).

Matter of Marriage of Roth, 865 P.2d 43 (Wash. Ct. App. 1994).

In Re the Marriage of Allen, 898 P.2d 1390 (Wash. Ct. App. 1995).

— Wash. Rev. Code § 26.09.170(3) — 22 cases

In re the Marriage of Cota, 312 P.3d 695 (Wash. Ct. App. 2013). “At issue here is whether the trial court had authority to order postsecondary educational support in light of RCW 26.09.170(3). See Major, 71 Wn. App. at 536 .”

Balch v. Balch, 880 P.2d 78 (Wash. Ct. App. 1994).

In re the Marriage of Sagner, 159 Wash. App. 741 (Wash. Ct. App. 2011).

Harmon v. Dep't of Soc. & Health Servs., 134 Wash. 2d 523 (Wash. 1998).

Harmon v. Dept. of Soc. & Health Serv., 951 P.2d 770 (Wash. 1998).

— Wash. Rev. Code § 26.09.170(4) — 2 cases

In Re Marriage of Griffin, 791 P.2d 519 (Wash. 1990).

In Re the Marriage of Sievers, 897 P.2d 388 (Wash. Ct. App. 1995).

— Wash. Rev. Code § 26.09.170(4)(a) — 1 case

In Re the Marriage of Sievers, 897 P.2d 388 (Wash. Ct. App. 1995).

— Wash. Rev. Code § 26.09.170(4)(b) — 1 case

In Re the Marriage of Brockopp, 898 P.2d 849 (Wash. Ct. App. 1995).

— Wash. Rev. Code § 26.09.170(4)(c) — 1 case

Matter of Marriage of Gillespie, 890 P.2d 1083 (Wash. Ct. App. 1995).

— Wash. Rev. Code § 26.09.170(4)(d) — 1 case

In the Matter of Marriage of Lee, 788 P.2d 564 (Wash. Ct. App. 1990).

— Wash. Rev. Code § 26.09.170(5) — 7 cases

In re the Marriage of Zandi, 391 P.3d 429 (Wash. 2017).

In re the Marriage of Schneider, 268 P.3d 215 (Wash. 2011).

Christy Jo Lyle v. Keith James Lyle, 199 Wash. App. 629 (Wash. Ct. App. 2017).

In re Marriage of Zandi (Wash. 2017).

In re the Marriage of: Jeffrey K. Newgard & Pennelopy Ann Newgard (Wash. Ct. App. 2017).

— Wash. Rev. Code § 26.09.170(5)(a) — 13 cases

In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). “Proper Procedure Is Petition To Modify ¶17 RCW 26.09.170 explains how and when a child support order can be modified.”

In Re The Marriage Of: Kenneth B. Kaplan, Res/cross-app. & Sheila Kohls, App/cross-res. (Wash. Ct. App. 2016).

Katie Michelle Wickstrom v. Vance Kalynn Wickstrom (Wash. Ct. App. 2019).

In the Matter of the Marriage of: Verity Battista & Alex Saha (Wash. Ct. App. 2021).

John Mason, V Tatyana Mason (Wash. Ct. App. 2018).

— Wash. Rev. Code § 26.09.170(5)(b) — 4 cases

Royal Fish, Sr., Appellant/cross-respondent v. Lisa Fish, Respondent/cross-appellant (Wash. Ct. App. 2017).

In Re The Marriage Of Pamela & Robert Flagella (Wash. Ct. App. 2017).

In re the Marriage of: Kert A. Carlson & Rebecca M. Carlson (Wash. Ct. App. 2019).

James Alan Clark v. Wendy Kristine Clark (Wash. Ct. App. 2020).

— Wash. Rev. Code § 26.09.170(6) — 8 cases

In re the Marriage of Zandi, 391 P.3d 429 (Wash. 2017).

In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). “Proper Procedure Is Petition To Modify ¶17 RCW 26.09.170 explains how and when a child support order can be modified.”

In Re the Marriage of Blickenstaff & Blickenstaff, 859 P.2d 646 (Wash. Ct. App. 1993). “He contends the trial court erred in finding him to be voluntarily unemployed and in imputing income to him, which thereby prevented him from demonstrating the substantial change in circumstances necessary for a modification under RCW 26.09.170-(1), or the change of income…”

In Re the Marriage of Shellenberger, 906 P.2d 968 (Wash. Ct. App. 1995).

Sekou Wiggs, Sr. v. Tamikya St. Clair (Wash. Ct. App. 2020).

— Wash. Rev. Code § 26.09.170(6)(a) — 7 cases

In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). “Proper Procedure Is Petition To Modify ¶17 RCW 26.09.170 explains how and when a child support order can be modified.”

In Re The Marriage Of: Kenneth B. Kaplan, Res/cross-app. & Sheila Kohls, App/cross-res. (Wash. Ct. App. 2016).

In the Matter of the Marriage of: Verity Battista & Alex Saha (Wash. Ct. App. 2021).

In Re The Marriage Of: Zeleke Kassahun v. Fanaye Ashagari (Wash. Ct. App. 2017).

James Alan Clark v. Wendy Kristine Clark (Wash. Ct. App. 2020).

— Wash. Rev. Code § 26.09.170(6)(b) — 4 cases

In re the Marriage of Geoff Merritt & Heidi Merritt (Wash. Ct. App. 2017).

James Alan Clark v. Wendy Kristine Clark (Wash. Ct. App. 2020).

Sekou Wiggs, Sr. v. Tamikya St. Clair (Wash. Ct. App. 2020).

In Re Marriage Of: Julie Davis, Resp/cross-app. v. Paul Davis, App/cross-resp. (Wash. Ct. App. 2014).

— Wash. Rev. Code § 26.09.170(7) — 5 cases

In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). “Proper Procedure Is Petition To Modify ¶17 RCW 26.09.170 explains how and when a child support order can be modified.”

Matter of Marriage of Aldrich, 864 P.2d 388 (Wash. Ct. App. 1993).

In Re the Marriage of Short & Short, 859 P.2d 636 (Wash. Ct. App. 1993).

Terry Lynn Mcdermott v. Scott William Mcdermott (Wash. Ct. App. 2019).

In Re The Marriage Of: Gregory Charles Morris v. Kelly Reyes (Wash. Ct. App. 2013).

— Wash. Rev. Code § 26.09.170(7)(a) — 9 cases

In re the Marriage of Morris, 309 P.3d 767 (Wash. Ct. App. 2013). “Proper Procedure Is Petition To Modify ¶17 RCW 26.09.170 explains how and when a child support order can be modified.”

In the Matter of the Marriage of: Verity Battista & Alex Saha (Wash. Ct. App. 2021).

Katelynn Skylar Roberts, V. Chad Michael Roberts (Wash. Ct. App. 2021).

Tami Sue Remick v. Enoch Thjs Remick (Wash. Ct. App. 2013).

In Re The Marriage Of: Kenneth B. Kaplan, Res/cross-app. & Sheila Kohls, App/cross-res. (Wash. Ct. App. 2016).

— Wash. Rev. Code § 26.09.170(7)(a)(i) — 4 cases

In Re The Marriage Of: Kenneth B. Kaplan, Res/cross-app. & Sheila Kohls, App/cross-res. (Wash. Ct. App. 2016).

In Re Marriage Of: Julie Davis, Resp/cross-app. v. Paul Davis, App/cross-resp. (Wash. Ct. App. 2014).

Thomas Baicy v. Danelle M. Shay (Wash. Ct. App. 2016).

Katelynn Skylar Roberts, V. Chad Michael Roberts (Wash. Ct. App. 2021).

— Wash. Rev. Code § 26.09.170(7)(c) — 1 case

Sekou Wiggs, Sr. v. Tamikya St. Clair (Wash. Ct. App. 2020).

— Wash. Rev. Code § 26.09.170(8) — 2 cases

Peggy Sue Smith, V. Scott William Smith (Wash. Ct. App. 2022).

— Wash. Rev. Code § 26.09.170(8)(a) — 7 cases

In re the Marriage of Scanlon, 109 Wash. App. 167 (Wash. Ct. App. 2001). “RCW 26.09.170 states in relevant part: (1) .”

In Re Marriage of Ayyad, 38 P.3d 1033 (Wash. Ct. App. 2002).

In re the Marriage of Abercrombie, 105 Wash. App. 239 (Wash. Ct. App. 2001).

— Wash. Rev. Code § 26.09.170(8)(b) — 2 cases

In Re the Marriage of Kelly, 934 P.2d 1218 (Wash. Ct. App. 1997).

Matter of Marriage of Roth, 865 P.2d 43 (Wash. Ct. App. 1994).

— Wash. Rev. Code § 26.09.170(9) — 2 cases

Jennifer J. Zacapu, V Andres Zacapu-Oliver, 368 P.3d 242 (Wash. Ct. App. 2016).

Marriage of Burch, 916 P.2d 443 (Wash. Ct. App. 1996).

— Wash. Rev. Code § 26.09.170(9)(a) — 2 cases

In re the Marriage of Waters, 63 P.3d 137 (Wash. Ct. App. 2002).

James Kim, V. Kum Kim, Aka Sarah Jung (Wash. Ct. App. 2023).

— Wash. Rev. Code § 26.09.170(9)(a)(i) — 1 case

Katelynn Skylar Roberts, V. Chad Michael Roberts (Wash. Ct. App. 2021).

— Wash. Rev. Code § 26.09.170(9)(b) — 1 case

Jennifer J. Zacapu, V Andres Zacapu-Oliver, 368 P.3d 242 (Wash. Ct. App. 2016).

— Wash. Rev. Code § 26.09.170(l)(a) — 7 cases

In re the Marriage of Ayyad, 38 P.3d 1033 (Wash. Ct. App. 2002). “3 Contrary to Rashid’s assertion, RCW 26.09.170-(l)(a) enforces automatic adjustments even when the parents’ combined income exceeds $7,000.”

In re the Marriage of Drlik, 121 Wash. App. 269 (Wash. Ct. App. 2004). “We hold that the trial court had authority under RCW 26.09.170 to suspend the maintenance obligation.”

In Re the Marriage of Pollard, 991 P.2d 1201 (Wash. Ct. App. 2000).

In re the Marriage of Kahle, 134 Wash. App. 155 (Wash. Ct. App. 2006).

Matter of Marriage of Gillespie, 890 P.2d 1083 (Wash. Ct. App. 1995).

— Wash. Rev. Code § 26.09.170(l)(b) — 2 cases

Matter of Marriage of Trichak, 863 P.2d 585 (Wash. Ct. App. 1993).

Matter of Marriage of Bucklin, 855 P.2d 1197 (Wash. Ct. App. 1993).

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.

Wash. Rev. Code § 26.09.170 (2026)

Notes:

RCW 26.09.170

Modification of decree for maintenance or support, property disposition—Termination of maintenance obligation and child support—Grounds. (Effective April 1, 2027.)

Notes: