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STATE
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STATUTES/CASES
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LIMITATIONS PERIOD
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Alabama
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Ala. Code 6-2-32; see also Leslie v. Beringer, 636 So. 2d 441 (Ala. Civ. App. 1994)
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20 years from date each installment becomes due
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Alaska
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Alaska Stat. 09.10.040 (actions), 09.35.020 (executions); see also State ex rel. Inman v. Dean, 902 P.2d 1321 (Alaska 1995) 1994)
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for actions,10 years from date each installment becomes due; for proceedings in aid of enforcement, 5 years unless "good cause" shown for delay
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Arizona
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Ariz. Rev. Stat. Ann. 25-503(J); see also Johnson v. Johnson, 195 Ariz. 389, 988 P.2d 621, 623 n.1 (Ct. App. 1999)
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request for judgment for arrears must be filed within 3 years after emancipation of all children; formal written judgments enforceable until paid in full
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Arkansas
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Ark. Code Ann. 9-14-235; see also Malone v. Malone, 338 Ark. 20, 991 S.W.2d 546 (1999)
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no limitations period on the enforcement of child support judgments
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California
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Cal. Fam. Code 4502; see also In re Marriage of Garcia, 67 Cal. App. 4th 693, 79 Cal. Rptr. 2d 242 (1997)
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no limitations period; judgments are enforceable until paid in full
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Colorado
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Colo. Rev. Stat. Ann. 13-52-102; see also In re Marriage of Aragon, 773 P.2d 1110 (Colo. Ct. App. 1989)
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20-year limitation period prescribed for execution upon judgments applies to each installment as it becomes due
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Connecticut
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see OCSE State Profile
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no limitations period
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Delaware
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Edwards v. Edwards, No. 80A-MR-12 (Del. Super. Ct. 1981); Pierce v. Higgins, 531 A.2d 1221 (Del. Fam. Ct. 1987)
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no limitations period on the enforcement of child support arrears
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District of Columbia
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D.C. Code Ann. 15-101; see also Mayo v. Mayo, 508 A.2d 114 (D.C. 1986)
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each installment of support has enforceable life of 12 years from the date it becomes due
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Florida
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Frazier v. Frazier, 616 So. 2d 575 (Fla. Dist. Ct. App. 1993); see also Garcia v. Guerra, 738 So. 2d 459 (Fla. Dist. Ct. App. 1999)
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proceedings to enforce support orders are equitable and not subject to a statute of limitations
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Georgia
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Ga. Code Ann. 9-12-60(d); see also Brown v. Brown, 269 Ga. 724, 506 S.E.2d 108 (1998)
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no limitations period on the enforcement of child support arrears
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Hawaii
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Haw. Rev. Stat. Ann. 657-5; see also Lindsey v. Lindsey, 6 Haw. App. 201, 716 P.2d 496 (1986)
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10 years from date each installment becomes due
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Idaho
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Idaho Code 5-245; see also Stonecipher v. Stonecipher, 131 Idaho 731, 963 P.2d 1168 (1998)
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action or proceeding to collect support arrearage must be filed before child reaches majority (18), plus 5 years
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Illinois
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735 Ill. Comp. Stat. Ann. 5/13-218; see also In re Marriage of Kramer, 253 Ill. App. 3d 923, 625 N.E.2d 808 (1993)
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20-year limitation on enforcement of judgments applies to collection of child support arrearage
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Indiana
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Ind. Code Ann. 34-11-2-10; see also Connell v. Welty, 725 N.E.2d 502 (Ind. Ct. App. 2000)
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action must be commenced before the earlier of child's emancipation or reaching majority (18), plus 10 years
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Iowa
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Iowa Code Ann. 614.1(6); State v. Stafford, 584 N.W.2d 242 (Iowa 1998)
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20 years from date each installment becomes due
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Kansas
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Kan. Stat. Ann. 60-2403(b); see also Gardner v. Gardner, 916 P.2d 43 (Kan. Ct. App. 1996); In re Marriage of Williams, 900 P.2d 860 (Kan. Ct. App. 1995)
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child support judgments do not become extinguished until they have been dormant for the period before the child's emancipation, plus 2 years
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Kentucky
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Ky. Rev. Stat. Ann. 413.090; see also Harvey v. McGuire, 635 S.W.2d 8 (Ky. Ct. App. 1982)
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15 years from emancipation or the time support delinquency is reduced to lump-sum payment, whichever occurs first
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Louisiana
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La. Civ. Code Ann. art. 3501.1; see also State v. Lee, 728 So. 2d 1042 (La. Ct. App. 1999)
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action to make executory arrearages of support subject to 10-year liberative prescription
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Maine
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Me. Rev. Stat. Ann. tit. 14, 752; see also Carter v. Carter, 611 A.2d 86 (Me. 1992)
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no limitations period on the enforcement of child support arrears
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Maryland
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Md. Code Ann., Cts. & Jud. Proc. 5-102(a); see also O'Hearn v. O'Hearn, 337 Md. 292, 653 A.2d 446 (1995)
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12 years from date each installment becomes due
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Massachusetts
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Mass. Gen. Laws Ann. ch. 260, 20; see also Child Support Enforcement v. Brenckle, 424 Mass. 214, 675 N.E.2d 390, 396 n.20 (1997)
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20 years from date each installment becomes due
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Michigan
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Mich. Comp. Laws 600.5809; Mich. Stat. Ann. 27A.5809; see also Rzadkowolski v. Pefley, 237 Mich. App. 405, 603 N.W.2d 646 (1999)
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10 years from the date that the last support payment is due under the support order
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Minnesota
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Minn. Stat. Ann. 541.04, 548.091; see also In re Marriage of Opp, 516 N.W.2d 193 (Minn. Ct. App. 1994); Bednarek v. Bednarek, 438 N.W.2d 9 (Minn. Ct. App. 1988)
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10 years from the date each installment becomes due
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Mississippi
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Miss. Code Ann. 15-1-43, 15-1-59; see also Glass v. Glass, 726 So. 2d 1281 (Miss. Ct. App. 1998)
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7-year statute of limitations begins to run from the date the child becomes emancipated
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Missouri
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Mo. Rev. Stat. 516.350.1, 516.350.2; see also In re Lombard, 994 S.W.2d 594 (Mo. Ct. App. 1999)
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each installment is presumptively satisfied 10 years after it becomes due, unless revived
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Montana
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Mont. Code Ann. 27-2-201(3); see also In re Marriage of Hopper, No. 98-580 (Mont. 12/09/99)
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10 years from the date each installment becomes due
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Montana
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Mont. Code Ann. 27-2-201(3); see also In re Marriage of Hopper, No. 98-580 (Mont. 12/09/99)
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10 years from the date each installment becomes due
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Nebraska
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Finnern v. Bruner, 167 Neb. 281, 92 N.W.2d 785 (1958); Freis v. Harvey, 5 Neb. App. 679, 563 N.W.2d 363 (1997)
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no limitations period on the enforcement of child support arrears
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Nevada
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Nev. Rev. Stat. Ann. 125B.050(3); see also State of Washington v. Bagley, 114 Nev. 788, 963 P.2d 498 (1998)
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no limitations period on the enforcement of child support arrears
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New Hampshire
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N.H. Rev. Stat. Ann. 508:4; see also Griffin v. Avery, 120 N.H. 783, 424 A.2d 175 (1980)
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6 years from the date each installment becomes due
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New Jersey
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N.J. Stat. Ann. 2A:14-5, 2A:17-56.23a
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20 years from the date each installment becomes due, subject to revival
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New Mexico
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N.M. Stat. Ann. 37-1-2; see also Padilla v. Montano, 116 N.M. 398, 862 P.2d 1257 (Ct. App. 1993)
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14 years from the date each installment becomes due
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New York
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N.Y. C.P.L.R. 211(e); see also Robinson v. Aspinall, 238 A.D.2d 255, 657 N.Y.S.2d 14 (1997); Werner v. Werner, 176 Misc. 2d 299, 671 N.Y.S.2d 626 (Sup. Ct. 1998)
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20 years from the date each installment becomes due
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North Carolina
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N.C. Gen. Stat. 1-47; see also State ex rel. George v. Bray, 130 N.C. App. 552, 503 S.E.2d 686 (1998)
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10 years from the date each installment becomes due
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North Dakota
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N.D. Cent. Code 14-08.1-05; see also Ruscheinsky v. Ulrich, No. 990388 (N.D. 06/29/00)
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no limitations period on the enforcement of child support arrears
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Ohio
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DeCamp v. Board, 94 Ohio App. 367, 115 N.E.2d 403 (1953)
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no limitations period on the enforcement of child support arrears
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Oklahoma
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Okla. Stat. Ann. tit. 43, 137; see also Aguero v. Aguero, 976 P.2d 1088 (Okla. Civ. App. 1999)
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no limitations period on the enforcement of child support arrears
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Oregon
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Or. Rev. Stat. 18.360, 107.135, 109.100(2); see also In re Marriage of Hovden, 104 Or. App. 514, 802 P.2d 89 (1990); cf. State v. Ramirez, 167 Or. App. 199, 2 P.3d 437 (2000)
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10 years from the date each installment becomes due, subject to renewal
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Pennsylvania
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42 Pa. Cons. Stat. Ann. 5527; see also Miller v. Bistransky, 451 Pa. Super. 433, 679 A.2d 1300 (1996); Morrissey v. Morrissey, 552 Pa. 81, 713 A.2d 614 (1998)
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6 years from date each installment becomes due; the only limitations periods that affect collections of domestic arrears are those applicable to enforcement efforts
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Rhode Island
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R.I. Gen. Laws 9-1-17, 15-5-16.3; Lippman v. Kay, 415 A.2d 738 (R.I. 1980)
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20 years from date each installment becomes due
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South Carolina
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S.C. Code Ann. 15-3-600; cf. Abba Equipment, Inc. v. Thomason, 335 S.C. 477, 517 S.E.2d 235 (Ct. App. 1999)
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10 years from date each installment becomes due
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South Dakota
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S.D. Codified Laws 15-2-6, 25-7-7.4; see also Hershey v. Curtis, 467 N.W.2d 484 (S.D. 1991)
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20 years from date each installment becomes due
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Tennessee
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Tenn. Code Ann. 36-5-103(g); see also Anderson v. Harrison, No. 02A01-9805-GS-00132 (Tenn. Ct. App. 01/07/99)
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no limitations period on the enforcement of child support arrears
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Texas
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Tex. Fam. Code Ann. 157.005(b)
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court retains jurisdiction to render judgment for past-due support until all support has been paid
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Utah
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Utah Code Ann. 78-12-22(2); see also State v. Jacoby, 975 P.2d 939 (Utah Ct. App. 1999)
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action must be commenced within 8 years after the date the last installment was due and obligee may only collect past-due amounts going back 8 years
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Vermont
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Vt. Stat. Ann. tit. 15, 606; see also Hixson v. Plump, 167 Vt. 202, 704 A.2d 1159 (1997)
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actions for unpaid support installments (which have not been reduced to judgment) must be brought no later than 6 years after child attains majority
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Virginia
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Va. Code Ann. 8.01-251; see also Arthur v. Commonwealth, No. 1762-98-3 (Va. Ct. App. 1999)
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20 years from the date the unpaid installments are reduced to a money judgment
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Washington
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Wash. Rev. Code Ann. 4.16.020(3), 6.17.020; see also In re Marriage of Capetillo, 85 Wash. App. 311, 932 P.2d 691 (1997)
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10 years from date each installment becomes due
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West Virginia
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W. Va. Code 38-3-18; see also Clay v. Clay, No. 26209 (W. Va. 1999)
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10 years from date each installment becomes due
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Wisconsin
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Wis. Stat. Ann. 893.16; Paterson v. Paterson, 73 Wis. 2d 150, 242 N.W.2d 907 (1976)
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20-year limitation period begins to run when child attains majority
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Wyoming
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Wyo. Stat. Ann. 1-16-503, 1-17-307, 20-2-113; see also Hollingshead v. Hollingshead, 942 P.2d 1104 (Wyo. 1997)
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each unpaid installment becomes dormant if execution is not issued thereon within 5 years; thereafter, may be revived within 21 years
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