The Fourth Appellate District reversed orders with directions. The court held as a matter of law that a retroactive modification of a pendente lite child and spousal support order that denied a spouse who was favored under the order her accrued temporary support was improper.

Deborah Goodman and Arthur Gruen were married in 1989. They had four minor children between ages ten and sixteen when Goodman filed for legal separation and for an OSC for child and spousal support in 2007.In October, Goodman and Gruen stipulated through counsel to Goodman’s primary custody of the children and to Gruen’s support. In April 2008, Gruen filed for dissolution and for an OSC regarding, among other things, child and spousal support. Gruen and Goodman stipulated to consolidation of their actions. They also contested the amounts of Gruen’s monthly income and of Goodman’s monthly income and expenses.