Background
Ilana Judith Grumberg and Marc Anthony Thompson-Kow, who were never married, raised twin daughters together until their relationship ended in 2020. After Grumberg restricted Thompson-Kow’s access to the children, he petitioned to establish paternity and obtain a parenting plan, timesharing, child support, and attorney’s fees. Grumberg admitted paternity and sought related relief.
Following a 2023 trial, the circuit court entered a paternity and timesharing judgment that gave Thompson-Kow majority timesharing and reserved jurisdiction over child support. A 2024 order imposed ongoing and retroactive support on Grumberg. In 2025, the court amended that order to correct the support start date, add later-accruing arrears, and award Thompson-Kow retroactive childcare expenses after the 2023 judgment. Grumberg appealed both the amended order and the 2023 judgment, but the appellate court dismissed the appeal of the 2023 judgment as untimely.
The Court’s Holding
The Fourth District affirmed the 2025 amended final order because Grumberg did not show reversible error in its three material changes: the corrected commencement date, the additional arrears, and the childcare-expense ruling.
Grumberg’s principal contention—that the court improperly imputed income and ordered support beyond her ability to pay—failed because support was calculated using the parties’ stipulated incomes. Her challenge to the underlying income determination concerned an unamended portion of the 2024 order and was outside the court’s jurisdiction. As to the added arrears, the court found no error; the trial court had authority to enforce its existing support order by ordering payment of arrears that accrued after the prior final order.
Key Takeaways
- A party is bound by a stipulated income used to calculate child support.
- An appeal from an amended order does not reopen review of unamended portions of an earlier final order.
- A trial court may enforce an existing child-support obligation by calculating and ordering payment of later-accruing arrears.
Why It Matters
The decision illustrates the limited scope of review when a later amended support order changes only discrete matters. Litigants must timely appeal an original final order if they seek to challenge determinations left unchanged by a later amendment.