Petropoulos

In this case, we review two orders entered in a marital dissolution action. One order modifies spousal support and the other awards sanctions.

In the first order, the trial court retroactively reduced the husband’s spousal support obligation and allowed him a partial recovery of his support overpayments. Both parties challenge that order. Arguing against the husband’s recovery of any support overpayments, the wife asserts that the trial court should have retroactively applied the statute in force at the time *167 modification was ordered. By cross-appeal, the husband seeks full reimbursement of all overpayments; he argues for retroactive application of a later amendment to the statute. As we explain below, we agree with the husband’s view. We therefore reverse the support modification order and remand with instructions to the trial court to give retroactive effect to the most recent amendments to the governing statute.

In the second order, the trial court awarded attorneys’ fees to the husband as a sanction against the wife. She challenges that award on procedural grounds. We find no error and affirm the fee award.

Facts and Procedural History

Nick Petropoulos…