showing a higher-paying former job voluntarily quit by the parent, from evidence showing that more lucrative work is currently available to the parent, or from evidence showing recent past earnings. Mir v. Mir, 39 Va.App. 119, 128, 571 S.E.2d 299, 304 (2002). The recent past earnings of a volun tarily unemployed parent often provides the most reasonable estimate of earning capacity. See, e.g., O’Hara v. O’Hara, 45 Va.App. 788, 798, 618 S.E.2d 859, 864 (2005) (affirming imputation of income “based on an average of wife’s income over the past several years”); Niemiec, 27 Va.App. at 451, 499 S.E.2d at 579 (reversing the trial court’s calculation of imputed income where evidence of recent past earnings did not support the amount); Bishop Cochran, 14 Va.App. at 831, 419 S.E.2d at 421 (<HOLDING>); see also Marian F. Dobbs, Determining Child &
holding that the trial court erred when it did not consider what the husband could have been reasonably expected to have earned  based upon the recent work history and other pertinent circumstances holding that when defendant failed to appear at scheduled suppression hearing the court could have decided the motion in defendants absence but it did not have the authority to refuse to consider it holding that due process required a hearing so the putative father would have an opportunity to present evidence to show as a factual matter that he could not reasonably have complied with utahs statutory requirements or deadlines because he could not reasonably have expected his baby to be born in utah holding that the district court erred when it failed to consider the presumption of irreparable harm holding that because the defendant could not have reasonably believed that the third person would have been justified in using force the trial courts finding of guilt was supported by substantial evidence