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]] <!-- citation-library:start --> ## Citation reference Brubaker v. Strum (2023) 87 Cal.App.5th 497, 303 Cal.Rptr.3d 579 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end -->