California, United States of America
The following excerpt is from K.A. v. R.J., B290796 (Cal. App. 2020):
We further reject Father's contention that Mother bore the burden of proof because the payments in 2009 and 2010 gave rise to a presumption that he made all previous payments. In support, he relies on Evidence Code section 636, which states, "The payment of earlier rent or installments is presumed from a receipt for later rent or installments."6 Father, however, provides no authority or analysis demonstrating that child support payments are governed by Evidence Code section 636. This alone is reason enough to reject his claim. (See Badie v. Bank of America (1998) 67 Cal.App.4th 779, 784-785 [when an appellant raises a point "but fails to support it with reasoned argument and citations to authority, we treat the point as waived"].)
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