State Codes and Statutes
Statutes > Connecticut > Title52 > Chap906 > Sec52-362Sec. 52-362. Income withholding and unemployment compensation for support. (a) For purposes of this section:
(1) "Dependent" means a spouse, former spouse or child entitled to payments under a support order, provided Support Enforcement Services of the Superior Court or the state acting under an assignment of a dependent's support rights or under an application for child support enforcement services shall, through an officer of Support Enforcement Services or the Bureau of Child Support Enforcement within the Department of Social Services or an investigator of the Department of Administrative Services or the Attorney General, take any action which the dependent could take to enforce a support order;
(2) "Disposable earnings" means that part of the earnings of an individual remaining after deduction from those earnings of amounts required to be withheld for the payment of federal, state and local income taxes, employment taxes, normal retirement contributions, union dues and initiation fees, and group life and health insurance premiums;
(3) "Earnings" means any debt accruing to an obligor by reason of such obligor's personal services, including any compensation payable by an employer to an employee for such personal services whether denominated as wages, salary, commission, bonus or otherwise, including unemployment compensation if a purchase of service agreement between the Commissioner of Social Services and the Labor Commissioner is in effect pursuant to subsection (e) of section 17b-179;
(4) "Employer" means any person, including the Labor Commissioner, who owes earnings to an obligor;
(5) "Income" means any periodic form of payment due to an individual, regardless of source, including, but not limited to, disposable earnings, workers' compensation and disability benefits, payments pursuant to a pension or retirement program and interest;
(6) "Obligor" means a person required to make payments under a support order;
(7) "Support order" means a court order, or order of a family support magistrate including an agreement approved by a court or a family support magistrate, that requires the payment to a dependent of current support, cash medical support, a specific dollar amount of child care costs or arrearage payments;
(8) "Unemployment compensation" means any compensation payable under chapter 567, including amounts payable by the administrator of the unemployment compensation law pursuant to an agreement under any federal law providing for compensation, assistance or allowances with respect to unemployment.
(b) The Superior Court and any family support magistrate shall issue an order for withholding pursuant to this section against the income of an obligor to enforce a support order when the support order is entered or modified or when the obligor is before the court in an enforcement proceeding. The court shall order the withholding to be effective immediately or may, for cause or pursuant to an agreement by the parties, order a contingent withholding to be effective only on accrual of a delinquency in an amount greater than or equal to thirty days' obligation. Any finding that there is cause not to order withholding to be effective immediately shall be based on at least (1) a written determination that, and explanation by the court or family support magistrate of why, implementing immediate income withholding would not be in the best interests of the child, and (2) proof of timely payment of previously ordered support in cases involving the modification of such support. Before the court or family support magistrate issues an order for withholding which is effective immediately against an obligor who is before the court or a family support magistrate, it shall inform the obligor of the minimum amount of income which is exempt from withholding under state and federal law, of such obligor's right to claim any applicable state or federal exemptions with respect thereto and of such obligor's right to offer any evidence as to why a withholding order effective immediately should not issue. If the court or family support magistrate issues an order for withholding to be effective immediately against a nonappearing obligor, notice shall be served subsequently upon the obligor in accordance with section 52-57 or sent by certified mail, return receipt requested, to the obligor's last known address, informing such obligor: (A) That a support order has been issued to be enforced by an income withholding order, (B) that an income withholding order has been issued effective immediately as part of the support order, (C) of the minimum amount of income exempt from withholding under state and federal law and of such obligor's right at the hearing on the support order to claim any other applicable state or federal exemptions with respect thereto, (D) of such obligor's right to a hearing, upon motion to the court, to offer any evidence as to why the withholding order effective immediately should not continue in effect, (E) of the amount of income received by such obligor which formed the basis for the support order against such obligor, and (F) of such obligor's right to move to modify the support order if such obligor's income has changed substantially or if the support order substantially deviates from the child support guidelines established pursuant to section 46b-215a.
(c) (1) If an obligor is delinquent on support payments on any prior order of support in an amount greater than or equal to thirty days' obligation, whether or not such order is subject to a contingent income withholding, such obligor shall become subject to withholding and the dependent shall cause a delinquency notice to be served on such obligor. The delinquency notice shall include a claim form and be in clear and simple language informing the obligor that (A) such obligor is delinquent under the support order in a specified amount and any additional amounts accruing until the effective date of the withholding order, (B) a withholding order has become effective against such obligor's income, (C) such obligor has fifteen days to request a hearing before the court or family support magistrate, and at such hearing such obligor may contest the claimed delinquency and the imposition of the income withholding, seek modification of the withholding order, and claim any lawful exemption with respect to such obligor's income, (D) such obligor has a right to seek modification of the support order by a proper motion filed with the court or family support magistrate, (E) eighty-five per cent of the first one hundred forty-five dollars of disposable income per week are exempt, and (F) the amount of the withholding order may not exceed the maximum percentage of disposable income which may be withheld pursuant to Section 1673 of Title 15 of the United States Code, together with a statement of such obligor's right to claim any other applicable state or federal exemptions with respect thereto. The claim form shall contain a checklist identifying the most common defenses and exemptions such that the obligor may check any which apply to the obligor and a space where the obligor may briefly explain the claim or request a modification of or raise a defense to the support order.
(2) An obligor shall become subject to withholding to enforce a prior order of support upon the request of the dependent regardless of any delinquency, and whether or not such order is subject to a contingent income withholding. In such cases, the dependent shall cause a notice to be served on such obligor which notice shall comply in all respects with the delinquency notice required under subdivision (1) of this subsection except that such notice shall not be required to allege a delinquency.
(d) An obligor may claim a defense based upon mistake of fact, may claim an exemption in accordance with subsection (e) of this section with respect to the withholding order, or may file by motion a modification or defense to the support order being enforced by the withholding, by delivering a signed claim form, or other written notice or motion, with the address of the obligor thereon, indicating the nature of the claim or grounds of the motion, to the clerk of the Superior Court or the assistant clerk of the Family Support Magistrate Division within fifteen days of receipt of notice. On receipt of the claim or motion, the clerk shall promptly enter the appearance of the obligor, set the matter for a short calendar hearing, send a file-stamped copy of the claim or motion to the person or agency of the state to whom the support order is payable and notify all parties of the hearing date set. The court or family support magistrate shall promptly hear and determine the claim or motion and notify the obligor within forty-five days from the date of the notice required under subsection (c) of this section of its determination. Unless the obligor successfully shows cause why the withholding order should not continue in effect, the court or family support magistrate shall order that the outstanding withholding order continue in effect against the nonexempt income of the obligor to the extent provided under subsection (e) of this section. The order shall be a final judgment for purposes of appeal. The effect of the withholding order shall not be stayed on appeal except by order of the court or a family support magistrate.
(e) A withholding order shall issue in the amount necessary to enforce a support order against only such nonexempt income of the obligor as exceeds the greater of (1) eighty-five per cent of the first one hundred forty-five dollars per week of disposable income, or (2) the amount exempt under Section 1673 of Title 15 of the United States Code, or against any lesser amount which the court or family support magistrate deems equitable. Subject to subsection (d) of section 46b-88, the withholding order shall secure payment of past and future amounts due under the support order and an additional amount computed in accordance with the child support guidelines established in accordance with section 46b-215a, to be applied toward liquidation of any arrearage accrued under such order, unless contested by the obligor after a notice has been served pursuant to subsection (c) of this section, in which case the court or family support magistrate may determine the amount to be applied toward the liquidation of the arrearage found to have accrued under prior order of the court or family support magistrate. In no event shall such additional amount be applied if there is an existing arrearage order from the court or family support magistrate in a IV-D support case, as defined in subdivision (13) of subsection (b) of section 46b-231. Any investigator or other authorized employee of the Bureau of Child Support Enforcement within the Department of Social Services, or any officer of Support Enforcement Services of the Superior Court, may issue a withholding order entered by the Superior Court or a family support magistrate pursuant to subsection (b) of this section, and shall issue a withholding order pursuant to this subsection when the obligor becomes subject to withholding under subsection (c) of this section. On service of the order of withholding on an existing or any future employer or other payer of income, and until the support order is fully satisfied or modified, the order of withholding is a continuing lien and levy on the obligor's income as it becomes due.
(f) Commencing no later than the first pay period in the case of an employer, or the date of periodic payment in the case of a payer of income other than an employer, that occurs after fourteen days following the date of service of an order for withholding and within seven business days of the date the obligor is paid thereafter, an employer or other payer of income shall pay sums withheld pursuant to the withholding order to the state disbursement unit, as required by subsection (p) of this section. The employer or other payer of income (1) shall specify the dates on which each withholding occurred and the amount withheld for each obligor on each such date, and (2) may combine all withheld amounts into a single payment to the state disbursement unit with the portion thereof which is attributable to each individual obligor being separately designated. If an employer or other payer of income fails to withhold from income due an obligor pursuant to an order for withholding or fails to make those payments, such employer or other payer of income is liable to such person for the full amount of income not withheld since receipt of proper notice in an action therefor, and the amount secured in the action shall be applied by such person toward the arrearage owed by the obligor. Such employer or other payer of income shall be subject to a finding of contempt by the court or family support magistrate for failure to honor such order for withholding, provided service of the order is made in accordance with section 52-57 or by certified mail, return receipt requested.
(g) All orders for withholding issued pursuant to this section shall take precedence over any execution issued pursuant to section 52-361 of the general statutes revised to 1983, or section 52-361a. Two or more orders for withholding may be levied concurrently under this section, but if the total levy in any week exceeds the maximum permitted under this section, all sums due shall be allocated by the state disbursement unit in proportion to the amount of such orders, giving priority in such allocation to current support.
(h) Service of any process under this section, including any notice, may be made in accordance with section 52-57, or by certified mail, return receipt requested. If service is made on behalf of the state, it may be made by an authorized employee of Support Enforcement Services, or by an investigator or other officer of the Bureau of Child Support Enforcement within the Department of Social Services or by an investigator of the Department of Administrative Services or by the Attorney General. Service of income withholding orders by Support Enforcement Services or by an investigator or other officer of said bureau upon an employer under this section may be made in accordance with section 52-57, by certified mail, return receipt requested, or by first class mail.
(i) An applicant for employment or an employee subject to an order for withholding issued pursuant to this section shall have the same protection from discipline, suspension or discharge by an employer as provided in section 52-361a.
(j) There shall be a fine of not more than one thousand dollars imposed on any employer who discharges from employment, refuses to employ, takes disciplinary action against or discriminates against an employee subject to an order for withholding issued pursuant to this section because of the existence of such order for withholding and the obligations or additional obligations which it imposes upon the employer.
(k) The employer shall notify promptly the dependent or Support Enforcement Services as directed when the obligor terminates employment, makes a claim for workers' compensation benefits or makes a claim for unemployment compensation benefits and shall provide the obligor's last-known address and the name and address of the obligor's new employer, if known.
(l) When an obligor who is subject to withholding under this section is identified as a newly hired employee pursuant to subsection (d) of section 31-2c, the state agency enforcing the obligor's child support order shall, within two business days after the date information regarding such employee is entered into the state directory of new hires, issue a withholding order to the employer of the employee in accordance with subsection (e) of this section.
(m) The provisions of this section shall be in addition to and not in lieu of any other remedy available at law to enforce or punish for failure to obey a support order.
(n) When a support order is issued in another state and the obligor has income subject to withholding derived in this state, such income shall be subject to withholding in accordance with the provisions of this section, upon the registration of the support order in accordance with sections 46b-213g to 46b-213j, inclusive. Notice of rights to the obligor and the obligor's right to contest such order are governed by sections 46b-213k to 46b-213m, inclusive.
(o) An employer who withholds the income of an obligor pursuant to a withholding order issued under subsection (e) or (l) of this section that is regular on its face shall not be subject to civil liability to any individual or agency for conduct in compliance with such order.
(p) All withholding orders issued under this section shall be payable to the state disbursement unit established and maintained by the Commissioner of Social Services in accordance with subsection (j) of section 17b-179. The state disbursement unit shall insure distribution of all money collected under this section to the dependent, the state and the support enforcement agencies of other states, as their interests may appear, within two business days. Each dependent who is not receiving child support enforcement services, as defined in subsection (b) of section 46b-231, shall be notified upon the issuance of a withholding order pursuant to this section, that such services are offered free of charge by the State of Connecticut upon application to the Bureau of Child Support Enforcement within the Department of Social Services.
(q) The judges of the Superior Court may adopt any rules they deem necessary to implement the provisions of this section and sections 46b-69a, 46b-178 and 52-361a and such judges, or their designee, shall prescribe any forms required to implement such provisions.
(1955, S. 3204d; 1959, P.A. 655; 1963, P.A. 33; 1969, P.A. 447, S. 3; P.A. 73-373, S. 38; P.A. 76-66; 76-436, S. 142, 681; P.A. 77-389; 77-594, S. 6, 7; 77-614, S. 70, 610; P.A. 78-217, S. 1; P.A. 80-149, S. 2, 3; P.A. 81-266, S. 1, 2; P.A. 82-433, S. 2; P.A. 83-295, S. 17; 83-400, S. 1; 83-581, S. 34, 40; P.A. 84-455, S. 4, 5; 84-527, S. 17, 18; 84-546, S. 115, 116, 173; P.A. 85-548, S. 1; P.A. 86-359, S. 36, 44; P.A. 87-483, S. 1, 3; P.A. 89-302, S. 1, 7; P.A. 90-213, S. 38, 56; P.A. 91-391, S. 10; P.A. 92-253, S. 4; P.A. 93-262, S. 1, 87; P.A. 96-268, S. 9, 34; June 18 Sp. Sess. P.A. 97-1, S. 71, 75; June 18 Sp. Sess. P.A. 97-7, S. 28, 38; P.A. 99-193, S. 6; P.A. 00-68, S. 4, 5; 00-196, S. 35; P.A. 01-91, S. 19-22; June Sp. Sess. P.A. 01-2, S. 27, 28, 69; June Sp. Sess. P.A. 01-9, S. 129, 131; P.A. 03-89, S. 6, 7; P.A. 07-247, S. 62, 63.)
History: 1959 act provided order directing execution may be against such lesser amount as court deems equitable, stipulated it be for payment of amounts due and which thereafter become due and extended application to order for support of wife; 1963 act added provision re executions issued in favor of welfare commissioner; references to commissioner of finance and control were added in 1967 in provision re executions in favor of welfare commissioner in conformity with provisions of 1967, P.A. 314, S. 1 which made finance and control department responsible for billing and collection of money due the state in child welfare cases, etc.; 1969 act removed welfare commissioner from purview of section and added provision allowing concurrent levy of two or more executions; P.A. 73-373 applied provisions to orders calling for support of husbands and substituted dissolution of marriage for divorce; P.A. 76-66 authorized execution against amounts exceeding $50 per week rather than $25 per week; P.A. 76-436 removed references to orders of courts other than superior court, reflecting transfer of all trial jurisdiction to superior court, effective July 1, 1978; P.A. 77-389 applied provisions to support orders generally where previously applicable to orders for "weekly" support; P.A. 77-594 allowed service of execution in favor of finance and control commissioner "by certified mail, return receipt requested", sent by the family relations officers of the issuing court; P.A. 77-614 replaced commissioner of finance and control with commissioner of administrative services; P.A. 78-217 based execution on amounts exceeding first $70 of disposable earnings per week rather than $50 and defined disposable earnings for purposes of section; P.A. 80-149 required that debtor's payments to administrative services commissioner be made monthly rather than at three-month intervals; P.A. 81-266 added provisions authorizing court to order execution at time obligation is established and allowing automatic execution if obligor defaults and fails to move court or show cause why the execution order should not go into effect; P.A. 82-433 designated previous provisions as Subsecs. (a) and (c) and added provisions for the execution against unemployment compensation in new Subsec. (b); P.A. 83-295 amended Subsec. (c) by replacing "the family relations officer" with "the family relations caseworker, the family relations counselor or a support enforcement officer" but failed to take effect, that subsection having been deleted by P.A. 83-400; P.A. 83-400 replaced previous section with revised provisions re definitions and procedures concerning wage executions and permitting such executions to be effective immediately; P.A. 83-581 amended Subsec. (c) to replace a reference to "section 52-361" with "section 52-361a" but failed to take effect as did P.A. 83-295; P.A. 84-455 amended Subsec. (a)(1) to allow enforcement of support orders by investigators of the bureau of collection services and amended Subsec. (j) to permit service of process by bureau of collection services investigators; P.A. 84-527 amended Subsec. (d) to provide that the claim form inform the obligor that $100 rather than $70 of disposable earnings per week are exempt, and amended Subsec. (g) to increase from $70 to $100 the amount of weekly disposable earnings exempt from execution or assignment; P.A. 84-546 made technical changes in Subsecs. (a), (i), (k) and (m); P.A. 85-548 revised section, substituting "an application for child support enforcement services" for "assignment of earnings" and "garnishment" for "execution", deleting former Subsec. (c) re dependent receiving assistance from state, and relettering remaining Subsecs. accordingly, amending Subsec. (d) by changing the time limit for payment of past due amounts by obligor from 20 to 15 days, amending Subsec. (e) providing procedure re defense based on mistake of fact to garnishment and motion for modification or defense to support order, amending Subsec. (g) re withholding of sums pursuant to garnishment by employer, adding Subsec. (k) re fine for employer who discriminates against employee subject to garnishment, adding Subsec. (l) re notification of termination of employment of obligor and adding Subsec. (n) re support order issued in another state; P.A. 86-359 added references to family support magistrate and assistant clerk of the family support division throughout section, amended Subsec. (b) re authority to order garnishment on prior support order provided delinquency notice is served on obligor, amended Subsec. (g) by changing "monthly" to "within ten days of the date the obligor is paid", amended Subsec. (h) re allocation of sums due by employer, giving priority to current support, and inserted new Subsec. (o) requiring IV-D agency to insure prompt distribution of money collected pursuant to section, relettering former Subsec. (o) as (p); P.A. 87-483 amended Subsec. (c) by deleting provision requiring that all past due amounts be paid within 15 days to stay garnishment; P.A. 89-302 amended Subsecs. (b), (e), (h), (j), (k) and (n) by changing "garnishment" to "order for withholding" or "withholding" or "withholding order", added "for cause or pursuant to an agreement by the parties" and deleted provision re delinquency notice by dependent upon obligor; amended Subsec. (c) by adding "on any prior order of support" after "payments", changed "garnishment" to "withholding" or "withholding order"; amended Subsec. (d) by deleting "to pay all amounts past due, or" after "fails" and changing "garnishment" to "withholding order"; amended Subsec. (f) by changing "garnishment" to "withholding order" and added provision re additional amount equal to 20% of current order or $10 weekly, whichever is greater, to be applied toward arrearage; and amended Subsec. (g) by changing "garnishment" to "order for withholding" or "withholding order", added provision requiring employer to specify dates on which each withholding occurred and amount withheld and after "court", added "or family support magistrate"; P.A. 90-213 changed references to the family division to the support enforcement division in Subdiv. Subsecs. (a)(1), (i) and (l) and deleted reference to support enforcement services of the family division in Subsec. (g); P.A. 91-391 added Subsec. (b)(2)(E) and (F) requiring notice of amount of income which formed basis for support order and of right to modify order if income changed substantially or if order substantially deviates from child support guidelines, amended Subsecs. (c) and (e) increasing exemption from $100 to $135 of disposable earnings per week and amended Subsec. (l) by requiring employer to notify if obligor makes claim for worker's compensation or unemployment compensation benefits; P.A. 92-253 amended Subsec. (a)(3) by adding phrase "including payments from retirement plans"; P.A. 93-262 authorized substitution of commissioner and department of social services for commissioner and department of human resources, effective July 1, 1993; P.A. 96-268 redefined "disposable earnings" by subtracting the amounts withheld for state and local income taxes from "disposable earnings", amended Subsecs. (c)(5) and (f)(1) by increasing $135 to $145, and amended Subsec. (g) by changing references to "bureau of collective services" to "state acting by and through the IV-D agency", effective July 1, 1996; June 18 Sp. Sess. P.A. 97-1 made technical changes in Subsec. (n) and added reference to Secs. 46b-213g to 46b-213j, inclusive, and notice of rights of obligor governed by Secs. 46b-213k to 46b-213m, inclusive, effective January 1, 1998; June 18 Sp. Sess. P.A. 97-7 amended Subsec. (a) by redefining "dependent" and "earnings" and adding definition of "income" in new Subdiv. (5), renumbering former Subdivs. (5) to (7), inclusive, as Subdivs. (6) to (8), inclusive, amended Subsec. (b) by deleting provision re filing of affidavit or court order for effective contingent withholding order and substituting provision that such order is effective on accrual of delinquency in amount greater than or equal to 30 days obligation and provision re finding not to order immediate withholding, added Subsec. (c)(2) re withholding to enforce prior order, whether or not such order is subject to contingent income withholding, deleted former Subsec. (d) and redesignated existing Subsecs. (e) to (l), inclusive, as Subsecs. (d) to (k), inclusive, amended Subsec. (e) by deleting provision re additional amount equal to 20% of order or $10 whichever is greater, by adding provisions re additional amount computed in accordance with child support guidelines, re application of such additional amount if there is an existing arrearage order from court or magistrate in IV-D case and re issuance of withholding order by Child Support Enforcement Bureau or Support Enforcement Division of the Superior Court, amended Subsec. (f) by making distinction between employer and payer of income other than employer and by changing "ten days" to "seven business days", amended Subsec. (g) by changing sums due allocated by employer to sums due allocated by IV-D agency in proportion to amount of orders, added Subsec. (l) requiring issuance of withholding order within two business days after information re employee who is new hire is entered into state directory of new hires, added Subsec. (o) re immunity from civil liability of employer who withholds income pursuant to withholding order that is regular on its face, redesignated former Subsecs. (o) and (p) as (p) and (q), respectively, amended Subsec. (p) by specifying that distribution be within two business days, replacing provision requiring "prompt distribution", and made technical changes throughout the section, effective July 1, 1997; P.A. 99-193 amended Subsecs. (c)(1)(E) and (e)(1) by adding 85% provision, amended Subsec. (f) by adding provisions re the state disbursement unit and a dependent in a IV-D support case, amended Subsec. (g) by changing "IV-D agency" to "state disbursement unit", amended Subsec. (p) by adding provisions re withholding orders payable to the state disbursement unit and distributions to the dependent, the state and the support agencies of other states, and made technical changes; P.A. 00-68 amended Subsecs. (a)(1) and (h) to substitute "Department of Administrative Services" for "Bureau of Collection Services"; P.A. 00-196 made a technical change in Subsec. (d); P.A. 01-91 amended Subsecs. (a)(1), (e), (h) and (k) by changing "the Support Enforcement Division" to "Support Enforcement Services" and further amended Subsec. (h) by adding provision re service of income withholding orders upon employer in accordance with Sec. 52-57, by certified mail or first class mail; June Sp. Sess. P.A. 01-2 amended Subsecs. (e) and (h) by duplicating change made by P.A. 01-91, and adding reference to service by an investigator or other officer of bureau in Subsec. (h), and amended Subsec. (f) to broaden applicability of withholding requirements and to condition contempt finding upon service of order in accordance with Sec. 52-57 or by certified mail, return receipt requested, effective July 1, 2001; June Sp. Sess. P.A. 01-9 revised effective date of June Sp. Sess. P.A. 01-2 but without affecting this section; P.A. 03-89 amended Subsec. (d) by deleting provision re stay of wage withholding order pending decision by court or family support magistrate on obligor's motion to modify or claimed defense against such withholding order, amended Subsec. (e) by adding provision re authority of Bureau of Child Support Enforcement or Support Enforcement Services to issue wage withholding orders entered by Superior Court or family support magistrate pursuant to Subsec. (b), and amended Subsec. (p) by adding provision re notice to dependents not receiving child support enforcement services that such services are offered free of charge upon application to the Bureau of Child Support Enforcement; P.A. 07-247 amended Subsec. (a)(7) by redefining "support order" to include cash medical support and specific dollar amount of child care costs and making technical changes, and amended Subsec. (e) by providing that amounts payable pursuant to a withholding order are subject Sec. 46b-88(d).
See Sec. 46b-69a re executions and earning assignments available in actions for dissolution of marriage, annulment and legal separation.
Amount of execution against pension benefits to be calculated under this section rather than Sec. 52-361 where it is for family support; court included this section with Sec. 52-361 by implication in exemption exception referenced in Sec. 52-352c(d). 178 C. 675.
Cited. 33 CA 395.
Payments from pension trust fund are susceptible to wage execution under this section and notification to trustees of such action is not required and therefore trustees need not be made parties. 37 CS 566. Cited. Id., 840.
Subsec. (b):
Cited. 28 CA 794. Court must provide notice to the party of party's statutory rights to claim exemptions or to present evidence that a withholding order should not issue immediately; court must then issue withholding order immediately unless cause exists for contingent wage withholding order. 51 CA 530.
Subsec. (d):
Doctrine of laches and equitable estoppel may apply under Subsec. and obligor in this case was entitled to assert doctrine of laches to stop wage withholding order where defendant had left state with child and not forwarded address as required by court order, and waited ten years to file any motion re support, and where obligor had made unsuccessful attempts to locate and contact the child. 108 CA 376.
Subsec. (e):
Cited. 240 C. 623.
