In a Decision – Dressner v. Dressner (an "Unreported Decision") >> the Court Held:
The statute prohibits the retroactive modification of a child support obligation to a date prior to the mailing of the notice of motion for such modification. Further, retroactivity is left to the sound discretion of the trial judge.
Following termination from his employment and efforts to obtain comparable employment, the Court terminated his alimony obligation as of the date of the order and modified the amount of child support in accordance with the child support guidelines. Even though the notice was mailed 19 months prior to the order, the family part court did not violate the statutory provisions by failing to order the obligation modified retroactively nor was there any abuse of discretion in such decision