GRUMBERG v. THOMPSON KOW (2026)

In this paternity action, Appellant, Ilana Judith Grumberg (“Mother”), appeals from the circuit court's 2025 amended final order affecting her child support obligation. Mother has not demonstrated reversible error. Thus, we affirm the 2025 amended final order.

I. Background

Mother and Father never married. They lived together and raised their twin daughters until their relationship ended in 2020. Father moved out, and Mother restricted his access to the children. Father later filed a petition to establish paternity and to obtain a parenting plan, timesharing, child support, and attorney's fees. Mother admitted Father's paternity and likewise requested shared parental responsibility, a timesharing schedule and parenting plan, child support, allocation of the tax dependency exemptions, and attorney's fees.

In 2023, after several years of litigation, the case proceeded to trial, after which the trial court entered a final judgment of paternity and timesharing. The judgment adopted Father's proposed parenting plan, awarded Father majority timesharing after considering the statutory best-interest factors, and reserved jurisdiction to calculate child support.

In 2024, the trial court entered a final order regarding child support. Among other things, that order required Mother to pay ongoing and retroactive child support, but declined to charge Mother with retroactive childcare expenses.

In 2025, the trial court entered an amended final order which corrected a clerical error concerning the commencement of Mother's child support obligation, calculated additional support arrears, and amended the prior ruling concerning retroactive childcare expenses by awarding Father those expenses for the period following the 2023 judgment.

Mother then filed this appeal. Her notice of appeal stated that she was appealing both the 2025 amended final order and the 2023 judgment, which she characterized as having become final when the 2025 amended final order was entered.

By prior order, we dismissed Mother's appeal of the 2023 judgment as untimely. We directed that the appeal would proceed only as to the 2025 amended final order.

II. The 2025 Amended Final Order

The 2025 amended final order changed the 2024 final order in three material respects: (1) correcting the commencement date of Mother's child support obligation; (2) adding child support arrears accruing after the 2024 final order; and (3) amending the treatment of retroactive childcare expenses.

Mother's briefing, however, does not identify reversible error in those amendments. She argues that the trial court improperly imputed income to her and thereby ordered support beyond her ability to pay. That argument is not supported by the record. The child support was calculated using the parties’ stipulated incomes. A pretrial stipulation “is binding not only upon the parties but also upon the trial and reviewing courts.” Waite v. Milo-Waite, 358 So. 3d 768, 773 (Fla. 4th DCA 2023) (citation modified) (quoting Palm Beach Cmty. Coll. v. State, Dept’ of Admin., Div. of Ret., 579 So. 2d 300, 302 (Fla. 4th DCA 1991)). Therefore, the trial court was bound by Mother's stipulated income and did not award support beyond her ability to pay. See id.

The 2025 amended final order's calculation of additional arrears did not materially amend that predicate income determination. Thus, to the extent Mother seeks review of the income determination itself, the argument concerns an unamended portion of the 2024 final order and falls outside our jurisdiction. To the extent her argument is directed to the 2025 amended final order's calculation of additional arrears based on the existing child support obligation, she has shown no error in that amendment. See Raskin v. Raskin, 625 So. 2d 1314, 1315 (Fla. 4th DCA 1993) (holding that the trial court had jurisdiction to order payment of support arrears accruing after the final judgment because the “trial court has inherent jurisdiction to enforce its own orders.”).

Because no reversible error has been demonstrated in 2025 amended final order, we affirm that order.

Affirmed.

Klingensmith, J.

Levine, J., and Siperstein, Caryn, Associate Judge, concur.