In re the Marriage of Forrester

Mother initiated this proceeding to establish and collect from father a child support arrearage. The principal issue is whether father and mother agreed that, in lieu of father paying mother child support as required by their dissolution judgment, father would pay mother’s credit card obligations, and, if so, whether their agreement is enforceable. An administrative law judge (ALJ) held that such agreements are not enforceable unless reflected in a modification of the dissolution judgment by the court, and he established father’s arrearage accordingly. The trial court reversed and credited…