Bielak v. Bielak, 210 A.3d 1117

James Bielak (Husband) and Elizabeth Bielak (Wife) separated in 2015; Wife sought alimony pendente lite (APL) and received interim APL beginning April 2016.
Wife had inherited an IRA from her father in 2006; she listed the IRA as non-marital in an inventory and later liquidated most of it during the divorce to pay living and legal expenses.
The parties reached a marital settlement agreement in August 2017 that terminated Husband's APL obligation effective July 13, 2017, but Husband sought de novo review to challenge treatment of Wife’s IRA distributions.
At a January 18, 2018 de novo hearing the trial court declined to treat the IRA distributions as income for support purposes and refused to reopen the APL award for retroactive modification.
Husband appealed solely on the ground that the IRA distributions are “income in respect of a decedent” under 23 Pa.C.S. § 4302 and therefore should have reduced or eliminated Wife’s APL.

Issue	Bielak (Husband) argument	Bielak (Wife) argument	Held
Whether distributions from an inherited IRA are "income" under § 4302 for APL/support calculation	Distributions are "income in respect of a decedent" and therefore should reduce Wife’s need for APL and permit retroactive modification	Inherited IRA corpus is non‑marital/inheritance not "income"; liquidation does not convert corpus to income for support	Court held IRA distributions are not income under § 4302; Humphreys controls and APL award was not retroactively modified

Humphreys v. DeRoss, 790 A.2d 281 (Pa. 2002) (inheritance corpus is not "income" under § 4302 and thus not available for support)
Maher v. Maher, 835 A.2d 1281 (Pa. 2003) (applied Humphreys without focusing on source of inherited funds)
Estate of Rose, 348 A.2d 113 (Pa. 1975) (defines "income in respect of a decedent" in the tax/estate context as post‑death income subject to income tax)
Carney v. Carney, 167 A.3d 127 (Pa. Super. 2017) (standard of review and purpose of APL explained)