C.D.G., Appellant/Cross-Appellee v. N.J.S., Appellee/Cross-Appellant

Summary

The court held that a trial court may award a dollar-for-dollar credit against a parent's child-support obligation for Social Security retirement dependent benefits paid to the child, even though the governing statute expressly addresses disability benefits but not retirement benefits. It also held that the trial court could order recoupment of support paid during the period covered by a later lump-sum award because the recoupment did not modify the support obligation retrospectively and the benefits created a fund representing a duplicate payment of support. The court therefore reversed the Court of Appeals and reinstated the circuit court's order; all members concurred.