The Virginia Court of Appeals held in Milligan v. Milligan, 6 VLW 195 (7/23/91), that the legislative adoption of tabular guidelines is in itself enough "change of circumstances" to justify upward modification of child support.
In Alexander v. Alexander, 406 S.E. 2d 666, 6 VLW 147, it was again emphasized how important it is that a trial court determine the "presumptive amount" from the guideline charts before determining anything else. The case was reversed for failure to resort to the guidelines before determining that the parties' recent written separation agreement controlled as to the amount of child support. Upon remand, the Court emphasized, the separation agreement provision may be a factor considered upon the decision whether or not to vary from the guideline amount.
However, from Scott v. Scott, 6 VLW 350, it looks like the agreement cannot even be a factor.
And yet in Watkinson v. Henley, 6 VLW 429, where a father was not invoking the SA to keep child support low, but seeking to escape a SA provision that tied him to a support figure above guideline, the trial judge was reversed for following the guideline rather than regarding the court as bound by the agreement.