Another useful holding recently was in Crank v. Crank. The case essentially deals with the issue of whether there are limits on how much a court can order to be paid toward past due child support or maintenance arrearages. The court said that a court must look to the Income Withholding for Support Act (750 ILCS 28/1) which caps payments at 50/60 percent of a person's disposable income depending on whether the support is current or past due.