Is a motion for retroactive child and spousal support a matter of enforcement rather than retroactive support?

I agree with the mother’s primary position and characterize her motion as one of enforcement. In Meyer v. Content, Chappel J. concluded as follows: Where a Separation Agreement or court order clearly establishes an obligation to make annual income disclosure and to adjust child support in accordance with increases in income, a subsequent proceeding by the recipient to pursue increased support in accordance with the terms of the agreement or order is a matter of enforcement rather than a claim for retroactive support. In these circumstances, neither the threshold test in D.B.S. for commencing a retroactive claim nor the time limitations set out in that case apply. The terms of the order or agreement clearly establish the legal right to pursue the relief in question, and the court should proceed directly to the merits of the case.[11]