Williams v. Williams (Tennessee 2017)
Tennessee statutes require that an initial support order contain a judgment for retroactive support or findings to support deviating from the requirement. In this divorce action, the court awarded primary custody of the children to father. The court ordered no current support because mother was receiving social security. Prior to the custody order, the children lived with their mother. The divorce decree did not award retroactive support or include the findings required for a deviation. The appellate court remanded the case for calculation of retroactive support.