Sheerer

I. BACKGROUND

Sheerer and Panas were a married couple that began dissolution proceedings in 2019. The couple have two children from their marriage and have joint physical custody of them on a 50/50 time share. In 2020 and 2021, the trial court issued several child support orders following hearings on the matter. Initially, in September 2020, the court ordered Panas to pay child support of varying monthly amounts, which were calculated as a function of the parties’ relative incomes each month. In November 2020, the court entered a new order with additional findings regarding Panas’s fluctuating income, and the court included a Smith-Ostler provision, 2 ordering “additional income received by either party in excess of the base income used in the initial support order” to be included in calculating additional child support. In December 2021, the court entered another new order, detailing the Smith-Ostler provision’s mechanics, calculating retroactive payments, and reaffirming that the Smith-Ostler provision would be prospectively “calculated on a monthly basis.” In June 2023, Sheerer moved to modify the existing child support order due to a change in both parties’ incomes and her…