Christopher Howard Marraro, II v. Janae Irene Haaland, 1635164

Marraro and Haaland divorced in 2014; Marraro moved to modify child support in Feb. 2016 and a hearing occurred Aug. 1–2, 2016. Parties stipulated Marraro’s income was $115,000.
Marraro’s employer offers a high-deductible health plan with an HSA/HRA-like employer contribution of $1,000/year (paid incrementally) and Marraro contributes pre-tax amounts each paycheck to the HSA.
Marraro argued he should receive credit for his pre-tax contributions (and employer contributions) so that those payments count as insurance/premium funding before Haaland must share unreimbursed medical expenses.
The trial court modified child support and ruled it would credit Marraro’s pre-tax contributions as the equivalent of premium payments but barred him from claiming those contributions as unreimbursed medical expenses until he had “fully funded the insurance for the year (or pays medicals up to the level of the annual funding).” The court required Marraro to keep records and present demands within 90 days.
Marraro appealed, arguing the court improperly required Haaland to pay only after Marraro’s HSA was exhausted, contrary to Code § 20‑108.2(D).
The Court of Appeals held the record was insufficient for review because key guideline worksheets and related calculations were not included in the appendix, so it affirmed the trial court.

Issue	Plaintiff's Argument (Marraro)	Defendant's Argument (Haaland)	Held
Whether the trial court erred by crediting appellant’s pre‑tax HSA contributions as equivalent of premium payments and delaying appellee’s obligation to pay unreimbursed medical expenses until the HSA/annual funding was exhausted	Trial court deviated from statutory rule (Code § 20‑108.2(D)) by making Haaland wait until Marraro “fully funded” insurance before she owed a share; no good‑cause findings for deviation	Trial court’s treatment is justified by the structure of the high‑deductible plan and the need to treat pre‑tax/HSA funding as funding toward coverage; record reflected parties’ calculations	Court affirmed — appeal dismissed for lack of a complete record (missing guideline worksheets and related calculations), so appellate review was impossible

Oliver v. Commonwealth, 35 Va. App. 286, 544 S.E.2d 870 (discussing appellate review limitations tied to the record)
Turner v. Commonwealth, 2 Va. App. 96, 341 S.E.2d 400 (appellate review limited to record)
Smith v. Commonwealth, 16 Va. App. 630, 432 S.E.2d 2 (court may act only upon facts in the record)
Commonwealth v. Williams, 262 Va. 661, 553 S.E.2d 760 (burden on appellant to provide sufficient record to show trial court error)