Voishan remains precedent in “above-the-guidelines” cases.
- Voishan v. Palma, 327 Md. 318 (1992).
In Voishan, the Court of Appeals addressed a mother’s Motion to Modify Child Support. The trial court granted the mother’s motion and ordered the father to double the amount of support he was paying for the parties’ only minor child. Evidence was presented in support of the motion for modification which revealed that the father was earning $145,000 per year and the mother was earning $30,000 per year. The combined adjusted actual income of the parties was therefore $175,000 a year or $14,583 per month. At the time, the Maryland Child Support Guidelines established through Md. Family Law Code Ann. § 12-204(e) only set guidelines for a combined adjusted actual income of $10,000 per month. In order to address cases, such as this, where the parties monthly income exceeded the guidelines, the legislature provided trial court’s with the discretion to set the amount of child support under Md. Family Law Code Ann. § 12-204(d).