In Baldwin v. Baldwin, the Virginia Court of Appeals in an opinion by Judge Kelsey, joined by Judge Annunziata and Senior Judge Overton, held among other things that legislative amendment to Va. Code 20-109(A) regarding spousal support could not be retroactive, invoking the constitutional bar against impairment of contracts.
Art. I, section 10 of the U.S. Constitution provides: "No state shall enter into any treaty, alliance, or confederation; grant letters of marque and reprisal; coin money; emit bills of credit; make anything but gold and silver coin a tender in payment of debts; pass any bill of attainder, ex post facto law, or law impairing the obligation of contracts, or grant any title of nobility."
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