Adcock v. COM., DEPT. OF SOCIAL SERVICES, 719 S.E.2d 304

Divorce decree in Alexandria 1966 required Adcock to pay $30/week for three children until majority; youngest emancipated 1982, ending obligation.
Houchens seeks to collect arrears from 1967–1982 despite termination date.
DCSE enforcement sought in 2006; circuit court allowed collection including arrears and interest with total $73,629.10.
Adcock raised statute-of-limitations defense under Code § 8.01-251(A); argued arrears were judgments beyond 20 years.
Court of Appeals affirmed circuit court; Adcock appealed to Supreme Court of Virginia.
Supreme Court reverses, holding that each missed payment becomes a judgment by operation of law and is subject to the 20-year limit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 8.01-251(A) bar collection of past due arrears from an ongoing support decree?	Houchens: statute applies only to liquidated judgments, not ongoing obligations.	Adcock: arrears are judgments created by operation of law and within 20-year limit.	Yes; § 8.01-251(A) applies to judgments, including those arising from unpaid ongoing orders.
Do installments become judgments on the date due if unpaid, triggering the 20-year period?	Houchens: not applicable; ongoing obligation not a liquidated judgment.	Adcock: unpaid installments become judgments when due.	Yes; each unpaid installment becomes a judgment on its due date.

Bennett v. Commonwealth ex rel. Waters, 15 Va.App. 135, 422 S.E.2d 458 (1992) (distinguishes ongoing unliquidated obligation from liquidated judgments for limitations)
Cofer v. Cofer, 205 Va. 834, 140 S.E.2d 663 (1965) (payments become vested and cannot be modified once due)
Hammers v. Hammers, 216 Va. 30, 216 S.E.2d 20 (1975) (ongoing support orders may be enforced and become judgments when due)
Eaton v. Davis, 176 Va. 330, 10 S.E.2d 893 (1940) (principles on ongoing support and judgments)
Mozley v. Prestwould Bld. of Dirs., 264 Va. 549, 570 S.E.2d 817 (2002) (text on statutory interpretation of plain terms)