Dart v. Dart
In a dissolution appeal, the Fourth DCA affirmed the husband's issues without discussion but reversed on the wife's cross-appeal from the denial of retroactive child support. Because the parties had entered agreed pretrial orders providing that the wife's temporary support application would be heard at trial and that any unpaid support would be awarded retroactively, the trial court erred in denying retroactive support based on the prenuptial agreement and a perceived lack of detriment to the children.
Key facts
- Husband and wife dissolved their marriage; the trial court denied the wife's request for retroactive child support despite parties' agreed pretrial orders stating that any unpaid support would be awarded retroactively at trial.
- The wife cross-appealed the denial of retroactive child support; the trial court had relied on the prenuptial agreement and a perceived lack of detriment to the children in denying the retroactive award.
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Why it matters
The opinion extends the 'strictly enforced' pretrial-stipulation doctrine (Jones, Palm Beach Polo Holdings) to agreed pretrial orders, giving family and civil litigators a tool to bind a trial court to the parties'… — full analysis with a trial
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