Aldrich v. Aldrich, 286 P.3d 504

2006 order modified custody and required Kristin to pay 100% of Joshua's travel costs in lieu of child support, without citing Rule 90.8.
Judge approved stipulation pro se; Joshua primarily resided with Kristin in Virginia, visiting Stephen in Alaska up to 12 weeks yearly.
In 2010 Stephen moved to recalculate past child support under Rule 90.3 and requested arrearages; sought retroactive support and enforcement of waivers.
Superior Court denied retrospective relief but allowed prospective relief; order did not address Rule 90.8 or specify the required computations if variation occurs.
Stephen appealed pro se; the appeal centered on whether past support could be awarded and on the validity of prospective relief.
Alaska Court of Appeals affirmed: past-support motion untimely under Rule 60(b)(1); prospective relief affirmed due to the 2006 order's divergence from Rule 90.8.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of Rule 60(b) motion	Aldrich argued the 2006 order was invalid under 90.3 and requested relief from error.	Aldrich contended the motion was timely under Rule 60(b) for relief from judgment.	Motion untimely under Rule 60(b)(1); not within reasonable time.
Retroactive vs prospective relief under Rule 90.3/90.8	Aldrich sought retroactive recalculation of support for 2006–2010.	Kristin argued no retroactive relief; court could grant prospective relief only.	Retroactive relief denied; prospective relief affirmed.

Laughlin v. Laughlin, 229 P.3d 1002 (Alaska 2010) (reversed trial court for failing to apply Rule 90.8; timeliness matters for Rule 60(b) relief)
Cook v. Cook, 249 P.3d 1070 (Alaska 2011) (standard governing Rule 60(b) relief and its timing)
Rowland v. Monsen, 135 P.3d 1036 (Alaska 2006) (untimeliness not a fundamental flaw that voids a judgment)
Morgan v. Morgan, 143 P.3d 975 (Alaska 2006) (general principles governing Rule 60(b) and relief from judgment)