It is practically axiomatic among family law practitioners that a parent who has primary child custody is entitled to receive child support. There can be exceptions to this practice, such as the case decided by the Pennsylvania Supreme Court captioned as Colonna v. Colonna, 581 Pa. 1.

The parties in Colonna were married in 1983 but separated in 1999, having had four children in the interim. Ultimately, the father secured primary custody of their four children and filed for child support against the mother. Through the support litigation, it was discovered that the father earns about $193,560 per year and the mother earns about $55,284 per year.