OCS/Pappas v. O'Brien
Vermont Supreme Court
67 A.3d 916 (2013)
Glenn Pappas (plaintiff) and Nan O’Brien (defendant) were divorced in California after six years of marriage and the birth of two sons, A.P. and P.P. The California court order awarded Pappas and O’Brien joint legal custody of the two sons, with O’Brien having primary physical custody and Pappas paying child support. Pappas moved to Oklahoma, while O’Brien and the children moved to Georgia, where O’Brien registered the California divorce and custody decree. Thereafter, O’Brien filed a petition in Georgia against Pappas to increase child support. The Georgia court granted O’Brien’s petition and explicitly stated that Pappas’s child-support requirement would cease if custody was later changed by a court of competent jurisdiction. Two years later, P.P. moved in with Pappas in Oklahoma. Pappas filed a petition in Oklahoma to gain physical custody of P.P. and to stop child-support payments for A.P., who had reached the age of majority. After a hearing, the Oklahoma court awarded custody of P.P. to Pappas and retroactively relieved Pappas of any child-support obligation. Additionally, the court ordered O’Brien to pay retroactive and ongoing child support to Pappas for the benefit of P.P. Later, P.P. returned to live with O’Brien in Georgia, and Pappas sought enforcement of child support for the time when P.P. was in his custody. An administrative law judge issued an order awarding Pappas retroactive child support. O’Brien then moved to Vermont. Pappas, through Vermont’s Office of Child Support (OCS) (plaintiff), filed a petition to register the Oklahoma support order pursuant to the Uniform Interstate Family Support Act (UIFSA). O’Brien filed a motion to set aside the support order. The Vermont court registered the Oklahoma order, and O’Brien appealed. The court of appeals affirmed. O’Brien filed documents to stay the Vermont court’s order and register the Georgia child-support order. OCS filed a motion to dismiss O’Brien’s action. The Vermont court granted OCS’s motion, and O’Brien appealed. The Supreme Court of Vermont consolidated the two appeals for review.
Rule of Law
Holding and Reasoning (Dooley, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 725,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 725,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,700 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.