Head v. Head
In Head v. Head, 24 Va. App. 166, 480 S.E.2d 780 (1997), the Court referred to the well established principle that "child support and spousal support are separate and distinct obligations based on different criteria."
In Head, the trial court reduced the husband's child support payments following legislative amendments to the statutory guidelines.
The wife then sought a dollar-for-dollar increase in spousal support corresponding to the trial court's reduction in child support.
The trial court rejected the wife's claim, noting that there was no evidence that the initial award was based upon a determination of her household's total financial needs.