Cavallari v. Martin, 169 Vt. 210, 732 A.2d 739 (Vt. 1999) was decided when the Revised Uniform Reciprocal Enforcement Act of 1968 (RURESA) was in force in Vermont; however, that Act did not apply because it covered only situations in which the child support obligor and obligee are in different states or different counties of the same state.
In Cavallari, all of the parties resided in the same county in Vermont. In its opinion, Vermont's Supreme Court noted that RURESA had been replaced by UIFSA, effective January 1, 1998.
The Court recognized that, unlike RURESA, Uniform Interstate Family Support Act (UIFSA) contains substantive restrictions that apply to modification decisions, one of which provides that a Vermont court may not modify any aspect of a child support order that may not be modified under the law of the issuing state.
Accordingly, under UIFSA, because a New York court could not modify the order to reduce its duration, a Vermont court cannot do so.
UIFSA, however, did not have any bearing on the outcome of the Cavallari case, since all of the parties resided in the same county in Vermont. In reversing the judgment of the Family Court, the Supreme Court specifically stated that the adoption of UIFSA "would yield a different result in a modification request first presented to the family court today." Cavallari, 732 A.2d at 740.