Sheets v. Shenk

45 Va. Cir. 330, 1998 Va. Cir. LEXIS 84
CourtSpotsylvania County Circuit Court
DecidedApril 8, 1998
DocketCase No. CH98-034
StatusPublished

This text of 45 Va. Cir. 330 (Sheets v. Shenk) is published on Counsel Stack Legal Research, covering Spotsylvania County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheets v. Shenk, 45 Va. Cir. 330, 1998 Va. Cir. LEXIS 84 (Va. Super. Ct. 1998).

Opinion

BY JUDGE WILLIAM H. LEDBETTER, JR.

The primary issues in this child support appeal are:

(1) Whether income should be imputed to the father, whose actual income is now considerably less than when his support obligation was established in 1995; and

(2) Whether all or part of a worker’s compensation settlement should be treated as income to the father for the purpose of calculating his support obligation.

The case is complicated by an agreement the parties made in April of 1997, at a time when the father was not working, that reduced his child support to $68.00 a week with the proviso that when he returned to work any new support order would be retroactive to the date of his re-employment.

Facts

The parties were married in 1982. Ashley, 15, and Adam, 9, were bom of the marriage. The parties separated in 1994 and were divorced the following year.

At the time of the divorce proceedings, the father was a truck driver for McLane Mid-Atlantic. He earned approximately $50,000.00 a year. The mother was not employed outside the home. At a pendente lite hearing on [331]*331January 18, 1995, custody was awarded to the mother, and the father was ordered to pay $885.00 a month as child support.

During the divorce litigation, the father sustained a work-related injury. Nevertheless, because the father continued to work, the parties agreed that he would continue to pay $885.00 a month. The court approved the agreement and incorporated it in the divorce decree on November 15, 1995. Future matters pertaining to support were transferred to juvenile court.

A few months later, the father petitioned the juvenile court for a reduction based on the worsening effects of his injury. On July 23, 1996, the juvenile court denied the relief. The court found that despite the injury, the father was still working, earning $56,000.00 a year, and the mother had no income.

At the end of 1996, the parties were in juvenile court again. The mother sought an increase in support; the father again sought a reduction.

Meanwhile, the father’s injury proved to be more serious than originally anticipated. He underwent “complex hip revision” surgery in February of 1997.

On April 14,1997, the juvenile court entered an agreed order reducing the father’s support to $68.00 a week with the proviso that any new order that increased his support after his return to work would be retroactive to the date of his re-employment. At the time, the father was receiving $300.00 a week in disability payments. The mother was earning approximately $20,000.00 a year. The parties contemplated that the father would return to work by July 27,1997; therefore, the case was continued on the docket until July 28,1997.

On June 4, 1997, the father reached a worker’s compensation settlement by the terms of which he received a lump sum payment of $48,000.00 and payment of all injury-related medical bills incurred through that date. According to the settlement, $15,000.00 of the lump sum was for “future medical expenses related to the accident,” and the balance, after deducting costs and attorney’s fees, was “prorated over the claimant’s statutory life expectancy ... resulting in a prorated weekly compensation rate of $12.10

The father went to work for Thompson Trucking on July 27, 1997. He explained that he had to give up his higher-paying job at McLane because he could no longer perform the strenuous work required of him there. In contrast, his truck driving employment at Thompson involves hauling mail and using “rolling carts” to load and unload the shipments.

On July 28,1997, the next hearing date, the case was continued. After two more continuances, the case was heard in juvenile court on November 25, 1997. The court set the father’s support obligation at $715.09 a month. [332]*332Consistent with the parties’ earlier agreement, the court made the award retroactive to July 27, 1997, except that the monthly amounts varied because of fluctuations in the mother’s child care expenses during the period of retroactivity.

The father appealed.

The case was heard de novo in this court on March 2, 1998. Counsel were invited to submit memoranda. Those memoranda have been received.

Presumptive Amount of Child Support

The first step in any child support case, including a modification proceeding, is to determine the presumptive child support obligation using the guidelines in Virginia Code § 20-108.2. Orlandi v. Orlandi, 23 Va. App. 21 (1996). In this case, except for the father’s worker’s compensation lump-sum settlement, the task is easy because the parties have stipulated all of the figures necessary to make the guidelines calculation.

The father’s actual monthly gross income is $2,034.00. The mother’s actual monthly gross income is $1,733.00. Using these stipulated sums, the parties’ combined actual monthly gross income is $3,767.00. The father’s income share is 54%, and the mother’s income share is 46%. The guidelines amount for basic child support is $817.00 a month. Adding the stipulated sums for health care coverage ($49.00) and child care costs ($178.00), the parents’ total obligation is $1,044.00. The father’s share of that obligation is $564.00.

Worker’s Compensation Settlement

For purposes of determining child support obligations, “gross income” is a defined term. It includes “all income from all sources” except those sources, such as public assistance, that are specifically excluded. Gross income includes, among other things, salaries, wages, commissions, royalties, pensions, dividends, interest, annuities, capital gains, worker’s compensation benefits, unemployment benefits, disability benefits, gifts, prizes, and awards. Virginia Code § 2Q-108.2(C).

Clearly, “benefits” refers to periodic payments that are designed to off-set loss of income due to disability, illness, temporary unemployment, work-related injury, and the like. Because such payments are a substitute for earnings, they are treated as earnings, i.e., income, for purposes of determining child support obligations.

[333]*333On (he other hand, the statute gives no guidance for the treatment of a parent’s receipt of a lump sum settlement of such benefits.

In Whitaker v. Colbert, 18 Va. App. 202 (1994), the Court of Appeals held that a personal injury settlement was not income because it was not apportioned between income elements (lost earnings) and capital recoupment elements (medical expenses, loss of earning capacity, pain and suffering). By implication, one could assume that if such a settlement were specifically apportioned, the income elements of the settlement would be treated as income. Such a result is largely theoretical, of course, because personal injury verdicts in Virginia are general verdicts, not apportioned among the elements of damages, and personal injury settlements are seldom, if ever, apportioned.

In this case, however, the father’s worker’s compensation lump sum settlement was apportioned. The settlement order of June 4, 1997, attributed $23,317.00 to “compensation,” which the parties agree constitutes “income.” The parties also agree that the portion of the settlement that went to payment of costs and attorney’s fees should not be considered.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Orlandi v. Orlandi
473 S.E.2d 716 (Court of Appeals of Virginia, 1996)
Edwards v. Lowry
348 S.E.2d 259 (Supreme Court of Virginia, 1986)
Whitaker v. Colbert
442 S.E.2d 429 (Court of Appeals of Virginia, 1994)
Hammers v. Hammers
216 S.E.2d 20 (Supreme Court of Virginia, 1975)
Antonelli v. Antonelli
409 S.E.2d 117 (Supreme Court of Virginia, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
45 Va. Cir. 330, 1998 Va. Cir. LEXIS 84, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheets-v-shenk-vaccspotsylvani-1998.