Reasin v. Reasin (In re Susan D.)
Case Summary
A divorce judgment ordered $1,750/month in child support for three children with no allocation between them. When each child reached adulthood, the father unilaterally reduced payments. The Court of Appeal ruled that retroactively allocating the lump sum among children after one ages out is not a prohibited retroactive modification โ it is simply calculating arrears after a support obligation has legally terminated.
Key Takeaway
California courts can allocate a lump-sum child support order among multiple children retroactively when one child emancipates, without running afoul of the ban on retroactive modifications.
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