Sutherby v. Astanina

Citations

• 2025 ND 166

Syllabus

A district court must credit a noncustodial parent for voluntary child support payments made during the pendency of an action when calculating past-due support obligations. When a court orders child support with a retroactive effective date, it must offset any past-due support owed by payments the noncustodial parent made to the custodial parent for the children's benefit during the relevant period.