A.S. v. District of Columbia ex rel. 13 Va. App. 13 Va. App. 147 Ill. App. A distinction in paternity actions must be made, however, between prospective support and retroactive support.
All states agree that in paternity actions, the guidelines apply to prospective support.
The states are split, however, as to whether the guidelines apply to retroactive support. West Virginina Department of Health and Human Resources, Child Advocate Office on Behalf of Jason Gavin S. by Diann E.S. v. The guidelines must be used as a rebuttable presumption in award modification actions regardless of whether the original order was established pursuant to support guidelines. The impact of the guidelines on modification proceedings is discussed in Chapter 5. 404 Pa. Super.