In the case of Fitzzaland v. Zahn, an appeal of a Frederick Circuit Decision by Judge Niklas, the Maryland Court of Special Appeals ruled that child support was properly awarded for an adult autistic dependant child who may be able to work in the future. In Fitzzaland, the dependant at issue displayed vocational proficiency in a number of areas. In addition, the dependant had worked at a few jobs. However, the court determined that the child both was not presently earning income and could not presently earn income.
