In re Marriage of Ostler Smith

In In re Marriage of Ostler & Smith (1990) 223 Cal.App.3d 33, the appellate court affirmed the trial court's "order for additional support, based on a percentage of husband's future bonuses." (Id. at p. 37.) It held that the then-governing statute allowed the trial court to "consider the future bonuses of a parent in determining income for purposes of fixing child support." (Id. at p. 52.) That case was decided under a predecessor statute, the Agnos Act (id. at p. 51; see Civ. Code, former 4720 et seq.) that provided for mandatory minimum child support, with trial court discretion to order additional support (id. at pp. 51-52, citing Civ. Code, former 4724).