Morris v. Morris (North Carolina)

The prohibition against retroactive modifications doesn’t come into play if the child support order is temporary. In 2014, the parents filed for divorce and, in 2015, the court entered a temporary support order for the father to pay support, which it then suspended in a 2016 order. In 2020, the court entered a final order and calculated the father’s child support starting in 2016. The father appealed the final order, arguing the 2016 order suspending support became a permanent order by virtue of its duration and it was error to set support back to 2016.

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Edwards v. Edwards (Kansas 1958)

An order of temporary support, in a divorce action, is merely a temporary provision for a child’s support until the final determination of the divorce action. The order for temporary support does not become a final judgment of support.

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