In the case of Brubaker v. Strum, the California Court of Appeal considered whether [[Cal. Fam. Code § 5241]] and other relevant statutes prevented an [[obligee]] from seeking an order determining arrearages from an [[obligor]] whose employer was subject to a valid [[income withholding order]] at the time of the alleged underpayments. The Court of Appeal concluded that [[Cal. Fam. Code § 5241]] does not prevent an obligor from enforcing payment of arrearages against an obligor whose employer was subject to a valid income withholding order at the time of the underpayments. The trial court's decision to deny the obligee's request and award sanctions against the attorney was overturned. ![[B317694.PDF]]