Department of Revenue v. Sean Michael Wolf and Christina Lian Guilliams

The issue in this case is whether an administrative law judge (“ALJ”) is statutorily authorized to modify an administrative order of child support retroactive to the date of service of the pleadings requesting modification. We hold that she is.

I

The Department of Revenue initiated the underlying proceedings to establish the support obligation for the child born of the parents, Sean Michael Wolf and Christina Lian Guilliams. A final administrative support order was entered on July 30, 2013, part of which was an obligation that Wolf pay for “past (retroactive) child support” that accrued during…