III. DISCUSSIONIn denying George credit for any actual child support he might have provided for the couple’s two children during the period of reconciliation and living together as a family in 2011, the trial court proffered four reasons. Three of those reasonsapply categorically in such a way as to preclude even the possibility of credit for a payor parent who had moved back in with the children. The three categorical reasons were: (1)George was not entitled to “Jackson credits” because the Jackson line of cases all involved total switch-overs of custody where the previously noncustodial parent became the sole custodial parent.1 (2) George should have brought a formal Order to Show Cause(OSC) based on changed circumstances when he moved back in with Allyson and the children. And (3) as a matter of statute (Fam. Code, §36022), the only relief allowed for support during reconciliation is when the support order is pendente lite, and this was not. The trial court also gave one factually-based reason: (4) George had to have a roof over his own head anyway, so the fact he moved in with Allyson and the children and paid rent to her father merited no credit. We address each of these considerations below. But before those reasons can be addressed adequately, a canvass of the relevant case law is required. No less thanthree distinct lines of California case law shed light on the problem of whether Jacksoncredits may be available in paternity cases involving reconciliations. There is also a small body of out-of-state litigation bearing on the issue. (See ALR Annot., Credit for Time Resided, supra, 104 A.L.R. 5th 605.) While none of these are determinative, they inform our decision.1The “Jackson line” consists of: Jackson, supra, 51 Cal.App.3d363, In re Marriage of Matthews(1980) 101 Cal.App.3d811, In re Marriage of Okum (1987) 195 Cal.App.3d176, and Trainotti, supra, 212 Cal.App.3d1072. 2All undesignated statutory references in this opinion are to the Family Code. 4

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Voiding or Modifying Retroactive Child Support Orders

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