Humphreys v. DeRoss

In Humphreys v. DeRoss, 567 Pa. 614, 790 A.2d 281 (2002), the Supreme Court construed a definition of "income" in Section 4302 of the Domestic Relations Law, as amended, 23 Pa. C.S. 4302: "Includes compensation for services, including, but not limited to, wages, salaries, bonuses, fees, compensation in kind, commissions and similar items; income derived from business; gains derived from dealings in property" and numerous other sources. The Supreme Court held that the italicized phrase applied only to "compensation for services" and not to all of the other categories of income enumerated; therefore an item claimed to be income under the definition was required to fit closely into an enumerated category. In that case the structure and punctuation of the definition clearly made compensation for services a distinct income category.