157 Wis. 2d 595, 460 N.W.2d 776 (WI. Ct. App. 1990)
(1) Arrears found by court in criminal non-support case are not res judicata and do not bind the family court. (2) Retroactive modification of arrears is a discretionary remedy under Schulz v. Ystad, where order was entered prior to August 1, 1987.
[ Full Opinion ]