Supreme Court of New Hampshire

In the Matter of Philip Borelli and Catherine Borelli

July 6, 2022

Summary

The Supreme Court of New Hampshire affirmed the circuit court’s order that Philip Borelli owes the child‑support arrearage because the court lacked authority to retroactively modify his support obligation. The Court applied the statutory provisions and its prior decision in White & White, holding that those rules apply retroactively to pending cases. It also reiterated the standard of review for discretionary support decisions and rejected the parties’ argument that a private agreement could alter the support order without judicial approval.