In a rare opinion that combines downward modification and payee imputation as to child support, the Court of Appeals says a couple of things which, were it not an unpublished opinion, would raise some doubt about the time-honored, if draconian, rules in this area. In Hamilton v. Hamilton, unpublished, 23 VLW 527 (10/7/08), the Court of Appeals said it was all right for a Fairfax Circuit Court to impute income to the mother, who had retired from the Navy and obtained (you might say) another job paying $24.55 per hour but then had (sort of) quit that and gone to work as a part-time social worker at $14.71 per hour. The only reason the mother gave for the job change was that she wanted to “work with troubled youth.” As for the mother’s interesting objection that the trial court had no business reducing the father’s support when he was in arrears or in some respect non-compliant with the existing order (in fact, he unilaterally halved his payments when a child aged out), the trial court’s reasoning was that he was not in contempt of the old order, because — listen up — because the element of willfulness hadn’t been proved, and the Court of Appeals affirms that.