On August 18, 2009, the Virginia Court of Appeals of Virginia affirmed a special case taken by Avery T. “Sandy” Waterman, Jr., Esq. The opinion is Carr v. CarrNo. 0096-09-1, arising out of Hampton Circuit Court.

In Carr, an adulterous pastor unsuccessfully sought modification of the spousal support and attorney fees award in favor or Mr. Waterman’s client. The appellate court upheld both awards, finding no abuse of discretion in the trial court rejecting the adulterer’s evidence as “incredible” because Mr. Waterman exposed his claimed income reduction was “voluntary and orchestrated by him”.