Va. Div. of Child Support Enforcement v. Curran

A party can’t appeal the amount of a civil appeal bond set by a JD&R district court to a circuit court without also appealing the JD&R court’s underlying substantive ruling. Here, the JD&R court set the appeal bond amount as equal to the amount it found the defendant owed in child support: over $27,000. He challenges this amount as bond (not as arrears), but there’s no mechanism for appealing a civil appeal bond separately from substantive legal issues.

The defendant’s appeal must be dismissed for lack of subject-matter jurisdiction.

Va. Div. of Child Support Enforcement v. Curran, No. KM18-399, Sept. 28, 2018. Fairfax Cir. (Oblon).



Categories: Opinions, Virginia Circuit Courts

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