Jeffrey Miller v. Megan Miller

Summary

The Supreme Court of Vermont held that a noncustodial parent is not eligible for an additional-dependent income adjustment under 15 V.S.A. § 656a. Because the statute permits only a full guideline-based deduction for a parent providing primary support, the mother's voluntary payments, travel expenses, visitation, and purchases for her son could not establish eligibility. The court therefore affirmed the family court's denial of the adjustment.