In re the Marriage of Kahle
Court of Appeals of Washington
1Opinion of the CourtCox, J.
¶1 At issue is whether an “automatic periodic adjustment” of child support ordered in a decree is self-executing—enforceable without further court order.1 We hold that such a provision is only enforceable by court order. Accordingly, we affirm the judgment for unpaid child support and medical expenses based on the original decree and remand for further proceedings.
¶2 The marriage of Randolph Kahle and Lyle Kahle was dissolved by decree in 1992. The terms of the decree include a provision for support of the couple’s two minor children and payment of health care costs, including medical…
2Cases cited14 opinions
- Department of Ecology v. Campbell & Gwinn, L.L.C.Washington Supreme Court · 2002
- State, Dept. of Ecology v. Campbell & GwinnWashington Supreme Court · 2002
- Smith v. Stillwell-SmithWashington Supreme Court · 1998
- State v. McCrawWashington Supreme Court · 1995
- State v. CostichWashington Supreme Court · 2004
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