Hicks v. Hicks

77 Va. Cir. 141, 2008 Va. Cir. LEXIS 142
CourtFairfax County Circuit Court
DecidedSeptember 29, 2008
DocketCase No. CL-2008-3675
StatusPublished

This text of 77 Va. Cir. 141 (Hicks v. Hicks) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hicks v. Hicks, 77 Va. Cir. 141, 2008 Va. Cir. LEXIS 142 (Va. Super. Ct. 2008).

Opinion

BY JUDGE GAYLORD L. FINCH, JR.

The parties entered into a Parenting, Support, and Property Settlement Agreement on February 14,2002. The agreement was ratified, affirmed, and incorporated into the Final Decree of Divorce, entered December 8, 2003. The parties have resolved their disputes over claims for reimbursement of the children’s extra-curricular and curricular activity expenses, daycare expenses, and unreimbursed medical expenses. The issues now are the claim for retroactive child support, made by the Defendant, and the claim for attorney’s fees, made by the Defendant and the Plaintiff, for bringing this action.

Opinion

The issues in this case can be broken down by the following five questions: (1) Did the Plaintiff and Defendant misrepresent their income from 2003 until the present? (2) Should support be awarded retroactively? (3) What were the parties’ incomes in the years in question in order to determine child support retroactively? (4) What are the parties’ incomes now and what should the amount of support be going forward? (5) Who, if anyone, should be awarded attorney’s fees?

[142]*142(1) Did Plaintiff and Defendant Misrepresent Their Income from 2003 until the Present? and (2) Should Support Be Awarded Retroactively?

The first issue is whether or not the Plaintiff and/or the Defendant misrepresented their income at any point between 2003 and the present. The parties Parenting, Support, and Property Settlement Agreement (“Agreement”) from February 14,2002, states in 4( 1) that with respect to future modifications “each party agrees to promptly inform the other of any change in his or her income and in the cost of day care. Either party may at any time request a recalculation of child support based upon a substantial change in circumstances.” 18(c) of the Agreement states, “If either party substantially misrepresents his or her income for the purposes of a spousal and/or child support determination, the support figure shall be recalculated retroactive to the date at which the correct information would have lead to a different support figure.”

Based on the tax returns submitted with the Defendant’s closing argument, it is clear that the Plaintiff failed to disclose substantial increases in income in 2004 and in 2006. The Plaintiffs child support obligation was different from what was agreed to in the Agreement for every year from 2003 until the present.

Plaintiffs defense is that he did not knowingly misrepresent his income. First, 18(c) of the Agreement does not require a knowing misrepresentation. The Agreement states, if either party substantially misrepresents their income for child support purposes, child support payments can be recalculated retroactively. Second, the Plaintiffs argument that he was unaware his capital gains and other sources of income other than his wages, tips, and compensation, were to be factored in for child support payments are unpersuasive. Plaintiffs employment background makes it difficult to believe he did not know other income sources, other than his wages, tips and compensation, were relevant for child support calculations.

Section 20-108.2(c) of the Code of Virginia defines gross income as, “income from all sources....” Based on the definition of gross income, it is clear that the Plaintiff misrepresented his income for at least 2003, 2004, and 2007. Again, whether this was a knowing misrepresentation or not is irrelevant based on the language of the parties’ Agreement. Plaintiff is, however, entitled to deductions of reasonable business expenses to offset his capital gains.

Also, under the definition of “gross income,” it is clear that bonuses, stock grants, interest income, dividends, and capital gains are to be included, as are gifts even though any type of gift is irregular income that may or may [143]*143not extend into the future, including any inheritance whether by will or intestate succession. Goldhamer v. Cohen, 31 Va. App. 728, 525 S.E.2d 599 (2000). Capital gains are clearly incorporated into gross income and should be included when determining gross income for the purpose of determining child support obligations.

Additionally, based on the work done to come to the original agreement with Mr. Larry Gaughan, it is clear that Plaintiff would have had to realize the figure agreed upon included more than just his salary (“earned income”). Plaintiff asserts that, based on deviations in other areas, it was understandable for Plaintiff not to think capital gains were included. This argument is unpersuasive based both on the parties’ interaction with Larry Gaughan in determining the original numbers and that the Agreement does not require a knowing misrepresentation, but rather only requires a substantial misrepresentation, which the Court believes occurred when the Plaintiff failed to disclose his capital gains income.

Based on the Plaintiffs misrepresentation of his income and the language of the parties’ Agreement, it is clear that a retroactive recalculation of child support is necessary.

Plaintiff argues that the Defendant misrepresented her income as well. Defendant’s response is that she feels she complied with paragraph 5(f) of the Agreement. Defendant interprets paragraph 5(f) as only requiring her to inform Plaintiff of change in her income, not the amount of the change. However, that is a very strained argument. Plaintiff even admits at trial, before later attempting to clarify, that change in income meant change in the amount of income. Thus, Defendant had a duty to inform Plaintiff of the amount of change in income. The provision would not make sense otherwise. Plaintiff could not determine if a substantial change of circumstances had taken place without knowing the amount of the change in Defendant’s income.

While Defendant is correct that the Agreement seemingly does not contain an “unclean hands” defense, that is only relevant to whether or not a defense exists for Plaintiffs misrepresenting his income. The lack of an “unclean hands” defense does not prevent the Court from finding the Defendant also misrepresented her income and such misrepresentations should be taken into account jointly with Plaintiffs misrepresentations when recalculating child support.

Plaintiff asserts that Defendant misrepresented her income since 2004. Plaintiff correctly argues that Defendant misrepresented her income for the years in question. Defendant did acknowledge at times to Plaintiff that she had received increases in income but she never disclosed the amount of the change in income, which the Agreement requires under the only reasonable interpretation.

[144]*144Plaintiff admitted at trial she received a job in 2004 that paid $ 110,000 but she did not tell the Plaintiff what her salary was. (Transcript p. 100.) Plaintiff did e-mail Defendant to ask what her salary was for 2004 until over three years later, though the parties’ Agreement did require a response within fifteen days. Defendant also failed to respond to a request in 2006 from Plaintiff asking her what her income was. (Defendant’s Ex. 2.) Defendant also failed to disclose her capital gain of $3 5,000 in 2005 until 2007. (Transcript p. 153.) Defendant admitted at trial that she did not tell Plaintiff about her income changes because she was afraid he would use the information to recalculate child support. (Transcript p. 114.)

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Related

Riggins v. O'BRIEN
559 S.E.2d 673 (Supreme Court of Virginia, 2002)
Shoup v. Shoup
556 S.E.2d 783 (Court of Appeals of Virginia, 2001)
Goldhamer v. Cohen
525 S.E.2d 599 (Court of Appeals of Virginia, 2000)
Howe v. Howe
516 S.E.2d 240 (Court of Appeals of Virginia, 1999)
Keyser v. Keyser
345 S.E.2d 12 (Court of Appeals of Virginia, 1986)
Moorman v. Moorman
62 Va. Cir. 497 (Roanoke County Circuit Court, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
77 Va. Cir. 141, 2008 Va. Cir. LEXIS 142, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hicks-v-hicks-vaccfairfax-2008.